SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

DIVISION OF
CORPORATION FINANCE

Mail Stop 3561
         May 27, 2010  Steven Lipscomb Chief Executive Officer ante5, Inc. One Hughes Drive, Suite 606 Las Vegas, NV 89169
Re: ante5, Inc.
  Amendment No. 1 to Regist ration Statement on Form 10
  Filed May 18, 2010   File No. 000-53952

Dear Mr. Lipscomb:
We have reviewed your responses to the comments in our letter dated May 14,
2010 and have the following additional comments.
 General

1. Please provide a detailed legal analysis of  why you believe that you will not be an
investment company as defined in th e Investment Company Act of 1940 after
consummation of the spin off.  Please addre ss in this regard the fact that a large
percentage of your post spin off assets appears to consist of securities.  In addition, address the nature of the royalty  stream and its status as a possible
security.  For example, do you have any intellectual property rights in the WPT
Business or merely a right to receive payments based upon the profitability of the WPT Business?
2. Please file any agreements detailing your rights in the post spin off assets and
describe the material terms of those agreement.

Letter to ante5, Inc. shareholders

3. Please revise the first bullet point to cl arify, if true, that the guarantee of $3
million is provided only by Peer less, not Party or advise.

Steven Lipscomb
ante 5, Inc.
May 27, 2010 Page 2  Business, page 8

4. We note your response to prior comment 12 and reissue in part.  Please remove
the reference to ClubWPT.com as "innovative" on page 9.
 Risk Factors, page 16

5. We note your response to prior comme nt 15, and your statement that Mr.
Limpcomb’s compensation has been determined and added to the Executive Compensation section.  However, the risk  factor continues to state that his
compensation has not been determined on page 16 and we can not locate the
addition of such disclosure in the Ex ecutive Compensation section on page 45.
Please clarify.

* * * * *
  As appropriate, please amend your regist ration statement in response to these
comments.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cove r letter with your amendment that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that  the filing includes all information investors
require for an informed investment decision.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.   Notwithstanding our comments, in the ev ent the company requests acceleration of
the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that:
• should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;
• the action of the Commission or the staff,  acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the company from its full
responsibility for the adequacy  and accuracy of the disclosure in the filing; and
• the company may not assert staff comment s and the declaration of effectiveness
as a defense in any proceeding initiat ed by the Commission or any person under
the federal securities laws of the United States.

Steven Lipscomb
ante 5, Inc. May 27, 2010 Page 3
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.   We will consider a written request for acceleration of the effective date of the registration statement as conf irmation of the fact that t hose requesting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te to the proposed public offering of the
securities specified in the above registration statement.  We will act  on the request and,
pursuant to delegated authority, grant acceleration of the effective date.
  We direct your attention to Rules 460 and 461 regarding requesting acceleration
of a registration statement.  Please allow ad equate time after the filing of any amendment
for further review before submitting a request for acceleration.  Please provide this request at least two business days in a dvance of the requested effective date.

You may contact John Sticke l at (202) 551-3324 with any questions.  If you need
further assistance, you may c ontact me at (202) 551-3412.
         R e g a r d s ,

         A m a n d a  R a v i t z          B r a n c h  C h i e f  –  L e g a l    cc: Via Facsimile (612) 642-8326

 David Polgreen, Esquire