SecProbe.io

Mail Stop 3561
April  18, 201 6

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

Re: Zev Ventures, Inc.
  Amendment No. 3 to Registration Statement on Form  S-1
Filed  March 22 , 201 6
  File No.  333-205271

Dear Mr. Turetsky :

We have reviewed your amended 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 a ppropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.   Unless we note
otherwise, our references to prior comments are to comments in our September 22, 2015  letter .

General

1. Please disclose that you are a shell company and provide the disclosures requested in
comment 2 of our letter dated July 23, 2015.  We continue to view your assets and
operations as  nominal.  Your revenue generating operations have consisted of buying
four seats at 20 New York Yankees games and selling those tickets on StubHub.  In
addition your assets as of December 31, 2015 consisted solely of $5,174 in cash and a
nominal amount of  ticket inventory.  While we note your response to us discussing past
and anticipated revenue growth, please note that the term “shell company” is defined in
Rule 405 of the Securities Act based on actual operations and assets without reference to
anticipa ted growth.  Alternatively, if your actual operations or assets are materially

Zev Turetsky
Zev Ventures, Inc.
April 18, 2016
Page 2

 different than those presented in your most recent filing you may provide us with detailed
facts and analysis demonstrating that you are not a shell company.

2. Please  revise disclosure regarding your revenues to be consistent with what is presented
in your financial statements .  In this regard we note from your financial statements that
you have generated some revenues, but page 1 states “to date we have recorded no
revenue,” and you “believe we can begin generating revenues within the first three
months following the successful completion of this Offering .”  Similarly, on page 2 you
state that “Zev Ventures, Inc. has had no minimal revenues to date  . . . .”

3. We note that you have provided data showing financial information through the period
ended December 31, 2015.  Please revise throughout your registration statement to align
your disclosures with these figures.  For instance, we note  that:

 In the risk factors sect ion on page 6, you state that you have accrued net losses
of $10,558 for the period from our inception on Dec ember 22, 2014 to June
30, 2015;
 In the executive compensation section on page 22, you present figures as of
June 30, 2015;
 In the beneficial owner ship section on page 23, you present figures as of June
30, 2015; and
 In the certain relationships and related transactions section on pages 23 and
24, you present figures as of June 30, 2015 and March 21, 2015.

4. Similarly, please revise throughout your registration statement to provide a current
picture of your operations.  In this regard, we note your disclosure on page 1 that you
“hope that we will be able to secure additional financing, and complete this Offering
within the coming months, to be able t o secure a team by Fall of 2015,” and on page 15
that “[t]hus far, the Company has purchased tickets for four adjacent seats at 20 New
York Yankees games during the 2015 MLB season.”

Summary Financial Information, page 2

5. Please revise to remove reference s to tables summarizing of your financial data since
none have been presented.

Dilution, page 11

6. Please revise to present your dilution information in the table on page 12 as of the most
recent date of December 31, 2015.  In this regard, we note that yo ur net tangible book
value per share would represent a negative amount per share.

Zev Turetsky
Zev Ventures, Inc.
April 18, 2016
Page 3

 Liquidity and Capital Resources, page 20

7. We note your disclosure that 3,000,000 shares were sold to Zev Turetsky on
December  22, 2015.  Based on the disclosures on pages 23 and 24, it appears this date
should reflect December 22, 2014 .  Please fix the discrepancy.

Financial Statements, page 25

8. Please revise to include the notes to the financial statements.

Report of the Independent Registered Public Accounting Firm , pag e 26

9. Please revise to provide an independent accountant’s report that refers to each period for
which audited financial statements are required.  In this regard, your auditor’s report
should reference both the year ended December 31, 2015 and the period f rom inception
(December 22, 2014) through December 31, 2014 and the respective balance sheet dates
for fiscal 2015 and 2014.

10. In addition, please note that the consent at Exhibit 23.1 should be similarly revised to
reference an audit report which covers all periods presented in the financial statements.

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 matters.  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
Office of Transportation and Leisure

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