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ATVROCKN

A Nevada Corporation

_________________________________________________________________________________

1813 Winners Cup Dr., Las
Vegas, NV 89117 Telephone: (702) 334-4008

November 2, 2011

VIA EDGAR TRANSMISSION AND EMAIL

U. S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E., Mail Stop 3030

Washington, D.C. 20549

Attn: Mr. Donald E. Field

Facsimile: 703-813-6967

Re:	ATVROCKN

Registration Statement on Form S-1

Filed September 19, 2011

File No. 333-176909

Dear Mr. Field:

On behalf of ATVROCKN (the “Company”),
the undersigned hereby submits a response to certain questions raised by the staff of the U. S. Securities and Exchange Commission
(the “Staff”) in its letter of comments dated October 14, 2011 (the “Comment Letter”) relating to the Company’s
Registration Statement on Form S-1 originally filed on September 19, 2011. Set forth below is the Company’s responses to
the Staff’s comments.

The Company’s responses are numbered to
correspond to the Staff’s comments. For your convenience, each of the Staff’s comments contained in the Comment Letter
has been restated below in its entirety, with the Company’s response set forth immediately under such comment.

General

1. We note that the selling securityholder acquired the shares to
be registered recently for the same price for which the shares are initially being offered,
and, upon conversion, the shares would represent approximately 86% and 100% of the company's outstanding shares
of common stock and outstanding shares of common stock held by non-affiliates, respectively. As a result, we note that the
offering appears to be an indirect primary offering. Given the nature and size of the offering, please advise regarding your basis
for determining that the offering is appropriately characterized as an offering that is eligible to be made pursuant to Rule 415(a)(1)(i)
of the Securities Act of 1933. Alternatively, identify Legal Beagle Services as an underwriter
on the cover page and throughout (not "may be deemed to be an underwriter") and include a fixed sales price to
the public for the duration of the offering. In addition, please make conforming changes throughout the prospectus (e.g. Calculation
of Registration Fee table, The Offering,

Plan of Distribution, etc.).

Response: We respectfully note the Staff’s comment, and
we submit that the following facts and circumstances which leads us to our conclusion that the offering by Legal
Beagle Services (the “Selling Shareholder”) pursuant to the Registration Statement is a secondary offering eligible
to be made under Rule 415(a)(1)(i).

The Staff’s primary guidance for analyzing
whether a transaction is a primary or secondary offering is set forth in the Compliance and Disclosure Interpretations, Interpretive
Response 612.09 (the “Interpretation”), provides that:

“It is important to identify whether a purported
secondary offering is really a primary offering, i.e., the selling shareholders are actually underwriters selling on behalf of
an issuer. Underwriter status may involve additional disclosure, including an acknowledgment of the seller’s prospectus delivery
requirements. In an offering involving Rule 415 or Form S-3, if the offering is deemed to be on behalf of the issuer, the Rule
and Form in some cases will be unavailable (e.g., because of the Form S-3 “public float” test for a primary offering,
or because Rule 415(a)(1)(i) is available for secondary offerings, but primary offerings must meet the requirements of one of the
other subsections of Rule 415). The question of whether an offering styled a secondary one is really on behalf of the issuer is
a difficult factual one, not merely a question of who receives the proceeds. Consideration should be given to how long the selling
shareholders have held the shares, the circumstances under which they received them, their relationship to the issuer, the amount
of shares involved, whether the sellers are in the business of underwriting securities, and finally, whether under all the circumstances
it appears that the seller is acting as a conduit for the issuer.” [emphasis added]

Here follows our analysis of each of the items set forth in the
last sentence of Interpretation 612.09 in the discussion below.

a. How long the selling shareholders have
held the shares and the circumstances under which they received them

On May 31, 2011, the Company issued 1,250,000
shares of its Series A Convertible Preferred stock to the Selling Shareholder in exchange for cash of $12,500. Had these
shares not been sold to the Selling Shareholder, the Company would not have had sufficient funds to design for the mold which was
used to produce its first product. Although the Series A Convertible Preferred stock can be converted to approximately 86%
of the common stock, the Company’s Articles of Designation for this Series of Preferred stock does not allow any conversion
to exceed 4.9% ownership in the Company.

Further, the Company respectfully submits that
the Selling Shareholder purchased the shares for investment purposes and did not acquire its securities with the purpose or intent
of effecting a distribution in violation of the Securities Act.

b. The selling shareholders’ relationship
to the issuer

The Selling Shareholder is not related to any
officer, director or other shareholder of the Company. Further, the Selling Shareholder is not an officer or director of the Company.
There are no arrangements or understandings between any of the Company’s officer/directors and the Selling Shareholder on
any matters, which includes the disposition of the stock owned by the Selling Shareholer.

The Company does not expect the Selling Shareholder
will have potential access to material non-public information. The Company does not expect that the Selling Shareholder will be
active in the market for the Company’s stock unless it is confident that any such activity is in full compliance with applicable
law.

In addition, and as discussed below, the Company
respectfully notes that the Staff has previously allowed sales by affiliates of an issuer through secondary offerings on Form S-3,
even in circumstances where such affiliates owned significantly more than one-third of the issuer’s public float.

c. The amount of shares involved

The Company acknowledges the Staff’s
concern with respect to the amount of convertible common share of the proposed offering being registered for resale relative to
the number of shares held by non-affiliates. We respectfully submit Interpretation H.20, regarding the use of Form S-3 to effect
a secondary offering, this Interpretation states: “A number of persons have asked whether Form S-3 is available for secondary
offerings to be made by affiliates of the issuer. The concern was that because the seller was an affiliate, the Division staff
might consider the secondary offering a sale on behalf of the issuer and, in reality, a primary offering requiring the affiliate-registrant
to meet the more stringent Form S-3 standards applicable to primary offerings by issuers. The Division staff had indicated, however,
that secondary sales by affiliates may be made under General Instruction I.B.3. to Form S-3 relating to secondary offerings, even
in cases where the affiliate owns more than 50% of the issuer’s securities, unless the facts clearly indicate that the
affiliate is acting as an underwriter on behalf of the issuer.” [emphasis added]

This interpretive position appears to indicate
that a Securityholder of well in excess of one-third of the public float can effect a valid secondary offering of its shares unless
other facts, beyond the mere level of ownership, indicate that the affiliate is acting as a conduit for the issuer. As detailed
below, Company respectfully advises the Staff that the Selling Shareholder is not acting as an underwriter or conduit for the Company.

d. Whether the selling shareholder is
in the business of underwriting securities

The Company respectfully advises the Staff
that the Selling Shareholder is not in the business of underwriting securities, but rather it is a private investor that purchased
securities in the Company for their own account. In addition, the Selling Shareholder has represented to the Company that the shares
were purchased for its own account for investment purposes only and not with an intention to distribute in violation of the Securities
Act. There is no factual basis that demonstrates that those representations and warranties are untrue. We note that the Selling
Shareholder is not a registered broker-dealer, has never served as an underwriter in any offering of securities, in the past has
utilized an underwriter to dispose of certain of its shares of the Company and will not be compensated in connection with the offering
under the Registration Statement (other than retaining all of the proceeds of the offering). Thus we respectfully submit that the
Selling Shareholder should not be construed as an underwriter.

e. Whether under all the circumstances it appears
that the seller is acting as a conduit

for the issuer

The Staff has recognized that affiliates of
an issuer are not necessarily conduits for the Issuer. In the Staff’s Interpretation D.38, the Staff responded regarding
whether affiliates of the issuer may rely on Rule 415(a)(1)(i) to register secondary offerings. The response states, in relevant
part, that: “Aside from parents and subsidiaries, affiliates of issuers are not necessarily treated as being the alter egos
of the issuers. Under appropriate circumstances, affiliates may make offerings which are deemed to be genuine secondaries.”

As stated above, the characteristics of the
Selling Shareholder are not consistent with offerings in which the selling shareholder is acting like an underwriter or as a conduit
for the issuer. In addition, as the Selling Shareholder is not in the business of underwriting securities and all of the proceeds
of the offering under the Registration Statement will be retained by the Selling Shareholder, the Company believes that the offering
the Company seeks to register is a valid secondary offering.

Conclusion

For the reasons stated above, the Company respectfully
requests that the Staff permit the offering by the Selling Shareholder pursuant to the Registration Statement as a secondary offering,
eligible to be made on a shelf basis under Rule 415(a)(1)(i).

To the second part of the first comment, we have revised the
document to identify the Selling Shareholder as an underwriter and we included a fixed sales price for the duration of the offering.

2. We note throughout the prospectus that you refer to
the registered preferred stock as "Series A Callable and Convertible Preferred," "convertible preferred," "preferred
shares," "Series A convertible preferred shares," and "Series A Preferred." Please revise to define the
registered preferred stock after the term's initial use and then to consistently refer to such defined term throughout the prospectus.

Response: Our Articles of Designation
filed with the Nevada Secretary of State classify these shares as “Series A Convertible Preferred Stock.” We have revised
the entire document to reflect this term.

3. We note the reference date of
August 31, 2011 used throughout the prospectus. Please revise the associated disclosure,
as applicable, to provide the information as of a more recent date.

Response: The reference
date has been updated to the date our amendment was signed, with the exception of financial information that ended August 31, 2011.

Registration Statement Cover Page

4. Please revise your "Primary Standard Industrial Classification
Code Number" to be 3714.

Response: We
have revised our "Primary Standard Industrial Classification Code Number to 3714.

5. Please provide
an explanation for the inclusion of footnote 5 to the "Calculation of Registration Fee" table since the filing of this
registration statement was your initial filing.

Response: We respectfully note the Staff’s comment. It
was an error on our part to include footnote 5 in this initial filing. Footnote 5 has been deleted.

Prospectus Cover Page

6. Please revise the prospectus cover page to more clearly
distinguish between the offerings being conducted by the company and the selling securityholder. For example, the first paragraph
indicates that the selling securityholder is offering 500,000 shares of your common stock which conflicts with your disclosure
elsewhere in the prospectus. The terms and conditions of each offering should be clarified. Refer to Item 501(b) of Regulation
S-K. Please also revise the prospectus throughout accordingly.

Response: We have revised the first paragraph of the
Prospectus Cover Page to state that we are registering up to 500,000 shares, for sale to investors by us at a price of $0.01 per
share.

7. We note your disclosure in the third paragraph that
the "offering will terminate when all 500,000 shares are sold or if not all of the shares
are sold, the offering will close on December 31, 2011, unless we terminate it earlier." Please revise to clarify whether
or not there may be extensions to the offering period. If there may be extensions to the offering
period revise to state the duration of such extensions. Refer to Item 501(b)(8)(iii) of Regulation S-K. Please also revise
the prospectus throughout accordingly.

Response: We have added disclosure to clarify that
management reserves the right to extend the offering for six months.

8. We note your disclosure in the second sentence of
the fourth paragraph that "[you] will not receive any of the proceeds from the shares of common stock sold by the selling
shareholders." Please revise to clarify that you will not receive any of the proceeds from the sale of preferred or common
stock by the selling securityholder. Please also revise the prospectus throughout accordingly.

Response: We
have revised to clarify that we will not receive any of the proceeds from the sale of preferred or common stock by
the selling securityholder.

9. We
note that the disclosure in the fifth paragraph related to the "penny stock" rules is focused
on your common stock. To the extent applicable, please revise to also address your preferred
stock. Please also revise the last sentence of this paragraph to clarify that your
preferred stock is not traded on NASDAQ or any recognized stock exchange. Please also revise the prospectus throughout accordingly.

Response: We have
revised our disclosure to include the our preferred stock.

10. We note your
disclosure in the sixth paragraph that you intend to apply for quotation of your common stock on the OTC Bulletin Board after the
closing of the offering. Please revise the summary to clarify that there is no trading
market for your preferred stock or common stock, you intend to apply for quotation of
your common stock on the OTC Bulletin Board, you will require the assistance of a market-maker
to apply for quotation and there is no guarantee that a market-maker will agree to assist
you. Please also revise to indicate, if true, that you have no current plans to apply
to have your preferred stock listed or quoted on any exchange or inter-dealer quotation
system. Refer to Item 501(b)(4) of Regulation S-K. Please also revise the prospectus throughout accordingly.

Response: We have updated our disclosure to include
we will require the assistance of a market-maker to apply for quotation and
there is no guarantee that a market-maker will agree to assist us. Further, no current
plans to apply to have our preferred stock listed or quoted on any exchange or inter-dealer
quotation system.

11. We note your cross-reference to the Risk Factors
section included after the sixth paragraph. Please revise to highlight this cross-reference
in prominent type or another manner. Refer to Item 501 (b)(5) of Regulation S-K.

Response: We have highlighted the Risk Factors cross-referen