August 1, 2008
VIA EDGAR CORRESPONDENCE ONLY
Mr. David R. Humphrey
Branch Chief
Division of Corporation Finance
U.S. Securities and Exchange Commission
Washington, D.C.
Re:
Actionview International, Inc.
Form 10-KSB for the Year Ended December 31, 2007
Form 10-QSB for the period ended March 31, 2008
File No. 033-90355
Dear Mr. Humphrey:
This letter is in response to your comment letter (the “Comment Letter”) dated July 21, 2008, with regard to the Form 10KSB filing of Actionview International, Inc., a Nevada corporation (“Actionview” or the "Company") originally filed on April 10, 2008.
The Company has included management’s assessment of internal control in its amendment to the Form 10KSB under Item 8A.
Additionally, the Company has reviewed the disclosures in its Form 10QSB filed May 15, 2008 for the period ended March 31, 2008. While the Company’s form type was designated as a Form 10-QSB, the disclosures meet the requirements for form 10Q. The Company will file all subsequent quarterly reports on Form 10Q, and its annual reports on Form 10K.
Finally, the Management of Actionview acknowledges that:
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the Company is responsible for the adequacy and accuracy of the disclosures in the filing;
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Securities and Exchange Commission (“SEC” or “Commission”) staff comments or changes to disclosure in response to SEC staff comments do not foreclose the Commission from taking any action with respect to the filing; and
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the Company may not assert SEC staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please feel free to contact me at this office with any further comments or questions. I would appreciate if you would send any further responses directly to me electronically or via facsimile, so Actionview can respond with a prompt response.
Thank you in advance for your courtesies.
ACTIONVIEW INTERNATIONAL, INC.
/s/ Steven Peacock
Steven Peacock, President
