SecProbe.io

July 23, 201 5

Zev Turetsky
Chief Executive Officer
Zev Ventures, Inc.
144-53 72nd Drive
Flushing, NY 11367

Re: Zev Ventures, Inc.
  Registration Statement on Form  S-1
Filed  June 26 , 2015
  File No.  333-205271

Dear Mr. Turetsky :

We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in yo ur
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.

General

1. Please provide us with copies of all written communications, as define d in Rule 405
under the Securities Act, that you, or anyone authorized to do so on your behalf, present
to potential investors in reliance on Section 5(d) of the Securities Act, whether or not they
retain copies of the communications.

2. Based on the information provided in your filing, it appears that you are a shell company
as defined in Rule 405 under the Securities Act .  We note that you have minimal assets,
no revenues to date and appear to have no or nominal operations.   Please disclose  that
you are a shell company and caution investors as to the highly illiquid nature of an
investment in the company ’s shares. Throughout the prospectus discuss the restrictions
imposed on such companies, including the unavailability of Rule 144 of the Securities

Zev Turetsky
Zev Ventures, Inc.
July 23, 201 5
Page 2

 Act of 1933 for resales of restricted securities , including on page 17 . Alternatively, please
provide us with detailed facts and analysis demonstrating that you are not a shell
company.

3. Please revise throughout to provide consistency and clarity for your es timated expenses.
In this regard, we note that on page 1 you state that you expect $50,000 in costs for one
year to be a reporting company, yet on page 9 you state that you expect $20,000 in costs
annually to satisfy reporting obligations.  Similarly, on page 5 you state that the minimum
cost to develop your business plan will be $40,000, yet on page 6 you  state that a
minimum of $100,000 will be necessary to operate for one year.

Risk Factors, page 4

Risks Related to the Company, page 4

4. We note your d isclosure on page 1 that a key element of your business plan is the ability
to purchase sporting event tickets “in bulk directly from primary ticket vendors such as
Ticketmaster.”  It appears that primary ticket vendors such as Ticketmaster limit ticket
purchases to a specified number of tickets for each event, known as a “ticket limit ,”
which  can be as strict as two per household .  Please add a risk factor discussing the
potential effect that these “ticket limits” may have on your business.   In addition pl ease
revise references to buying in “bulk” on pages 1 and 15 to explain how such purchases
will be possible in light of these limitations.   In the alternative please tell us why such
revisions are not necessary.

5. Please add a risk factor discussing the risk that you may not be successful at selling
tickets you purchase at a markup  above the price you paid , or please tell us why such
disclosure is not necessary .  We note throughout the prospectus that you appear to take as
a given that you will be able to  sell at a markup.

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 the information the Securities Act of 1933 and
all applicable Securities Act rules require.  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 event you request acceleration of the effective date
of the pending registration statement, please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commiss ion from taking any action with
respect to the filing;

Zev Turetsky
Zev Ventures, Inc.
July 23, 201 5
Page 3

  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 ac curacy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for acceleration.  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time for us to rev iew any amendment prior to the requested effective date of the
registration statement.

You may contact Heather Clark at (202) 551 -3624  or Jean Yu  at (202) 551 -3305  if you
have questions regarding comments on the financial statements and related matte rs.  Please
contact  Ryan Adams at (202) 551 -3191  or me at (202) 551 -3859  with any other questions.

Sincerely,

/s/ John Dana Brown

John Dana Brown
Attorney Advisor

cc: William Eilers
 Eilers Law Group, P.A.