PENGRAM CORPORATION
1200 Dupont Street, Suite 2J
Bellingham, WA 98225
Tel: (360) 255-3436
July 12, 2010
THE UNITED STATES SECURITIES
AND EXCHANGE COMMISSION
Division of Corporation Finance
100 F Street, N.E.,
Washington, DC 20549-4628
Attention: H. Roger Schwall, Assistant Director
Dear Sirs:
| Re: | Pengram Corporation (the “Company”) | |
| - | SEC File No. 000-52626 | |
| - | Annual Report on Form 10-K for the Fiscal Year Ended November 30, 2009 filed March 16, 2010 | |
As requested in your comment letter dated June 10, 2010 (the “Comment Letter”), we hereby acknowledge as follows:
| (a) | The Company is responsible for the adequacy and accuracy of the disclosure in the filing; |
| (b) | Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
| (c) | The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Thank you for your assistance. Please call with any questions.
Very truly yours,
PENGRAM CORPORATION
/s/ Richard W. Donaldson
_____________________________
RICHARD W. DONALDSON
Chief Executive Officer, Chief Financial Officer,
President, Secretary and Treasurer
