Wind Works Power CORRESP Correspondence with SEC

WINDWORKS [windworksseccommentletter001.jpg] POWER

June 10, 2011

Ethan Horowitz

Branch Chief

Securities and Exchange Commission

Washington, D.C. 20549

Re:

Wind Works Power Corp.

Form10-K for the FiscalYear Ended June 30, 2010

Filed October 13, 2010

File No. 333-113296

Dear Mr. Horowitz:

The following is filed in response to the Commission’s comment letter dated May19, 2011.

With respect to comment 1: We have paginated our amended annual report together

with the financial statements included therein.

With respect to comment 2: Our correct phone number is (613)226-7883 and we

have made the change in the amended annualreport.

With respect to comment 3: We have updated the trading symbolto WWPW in the

amended annual report.

With respect to comment 4: We have deleted the selected financial information

disclosure.

With respect to comment 5: See response to comment 4.

With respect to comment 6: We have amended the annualreport to report our net

loss for the year ended June 30, 2010 totaled $(2,477,370).

With respect to comment 7: We have amended the annualreport to report our long

termassets at June 30, 2010totaled $3,945,484.

346WaverleyStreet

3042 Concession 3 Adjala,

WWPW.OB

Ottawa,ON,K2P0W5

Hockley Valley Palagrave, Ontario,

WWW.WINDWORKSPOWER.COM

R5E1.F

Canada L0N1P0

WINDWORKS [windworksseccommentletter002.jpg] POWER

With respect to comment 8: We have amended our financial statements to designate

Wind Works as a “development stage” company.

With respect to comment 9: We have revised our balance sheets, statements of

operations and statements of cash flows to reflect ontheir face related partytransactions.

10.

With respect to comment 10: We capitalize developmentalwind farmacquisition

costs in accordance with ASC 350-30-30, which states that an intangible asset that is acquired either

individuallyor with a groupof other assets (but not those acquired in a business combination) shall

be initially measured based onthe guidance included in paragraphs 805-50-15-3 and 805-50-30-1

through 30-4, which states that assets are recognized based ontheir cost to the acquiring entity.

We acquire and develop wind parks, which we believe we will be able to lease or sellto

operating utilitycompanies or other companies desiring to purchase wind turbines and erect the

necessarypower lines. We believe our wind projects have indeterminable useful lives and

accordinglythe costs of internally developing, maintaining or restoring these wind parks after

acquisition are expensed as incurred in accordance with 350-30-25-3.

Wind projects are reviewed for impairment annually. In accordance with ASC 360, the

impairment test consists of a comparison of the fair value of an intangible asset with its carrying

amount. If the carrying amount of an intangible asset exceeds its fair value, an impairment loss shall

be recognized in an amount equalto that excess. We determined that the fair value of our wind

projects exceeded the carrying amount as at June 30, 2010. Specifically, we determined that ongoing

development of the projects was favorable and expected proceeds onthe sale of the projects exceed

carrying values, and as such no impairment was recorded.

11.

With respect to comment 11: We have amended footnote number 2 as requested.

The undersigned acknowledges that:

 The Company is responsible for the adequacyand accuracyof the disclosure in the filing.

 Staff comments or changes to disclosure in response to staff comments do not foreclose the

Commission fromtaking anyaction with respect to the filings; and

 The Company may not assert staff comments as a defense in any proceeding initiated by the

Commission or anyperson under the federalsecurities laws of the United States.

346WaverleyStreet

3042 Concession 3 Adjala,

WWPW.OB

Ottawa,ON,K2P0W5

Hockley Valley Palagrave, Ontario,

WWW.WINDWORKSPOWER.COM

R5E1.F

Canada L0N1P0

WINDWORKS [windworksseccommentletter003.jpg] POWER

Should you have further questions, please do not hesitate to contact me or our securities

counsel, Jeffrey Klein at (561)953-1126.

Sincerely,

/s/W. Campbell Birge

W. CampbellBirge

Chief FinancialOfficer

346WaverleyStreet

3042 Concession 3 Adjala,

WWPW.OB

Ottawa,ON,K2P0W5

Hockley Valley Palagrave, Ontario,

WWW.WINDWORKSPOWER.COM

R5E1.F

Canada L0N1P0

Wind Works Power (WWPW) Inactive CORRESPCorrespondence with SEC