BILLET FINDER INC.
1894 CLARENCE STREET
SARNIA, ONTARIO
N7X 1C8 CANADA
April 13, 2011
UNITED STATES SECURITIES
AND EXCHANGE COMMISSION
100 F Street, N.E., Mail Stop 4631
Washington, D.C. 20549
Attn: Maryse Mills-Apenteng
Re: Billet Finder Inc.
Registration Statement on Form S-1 Filed March 3, 2011
File No. 333-172590
In response to your letter dated March 30, 2011 we have filed an amendment to the S-1 which was originally filed March 30, 2011.
Cover Page
1. This is not an initial public offering by the Company, but rather a secondary offering by the existing selling shareholders.
Summary, page 3
2. Revised
Billet Finder Inc., page 3
3. Revised
Risk Factors
General
4. Risk factor Added
5. Risk factor added
6. Risk factor added
“Because our president has only agreed to provide his services on a part-time basis…, page 5
7. Revised. The other businesses mentioned in the referenced risk factor have since been concluded.
Selling Shareholders, page 9
8. We have revised the Registration Statement in the section entitled "Selling Shareholders" and throughout so that the number of shares beneficially owned by Catherine Tully takes into account the number of shares owned by her husband, Kerry Tully, and vice versa.
Market for Common Equity and Related Stockholder Matters
Rule 144 Shares, page 24
9. Revised
Auditor’s Report, page 24
10. Revised
Liquidity and Capital Resources, page 36
11. Revised
Directors, Executive Officers, Promoters and Control Persons, page 37
12. Revised
13. Revised accordingly.
Certain Relationships and Related Transactions, page 41
14. Revised accordingly.
Item 17. Undertakings, page 46
15. Revised
Signatures, page 47
16. Revised
Yours truly,
/s/ Kerry Tully
Kerry Tully
President