Aventura Holdings, Inc.
5555 Anglers Avenue
Suite 9
Ft. Lauderdale, Florida 33312
305.937.2000
August 5, 2008
William Schroeder, Staff Accountant
Hugh West, Branch Chief
United States Securities and Exchange Commission
Mail Stop 4561
Washington, DC 20549
Mr. Schroeder and West:
This correspondence is in response to your July 18, 2008 comment letter regarding the inadequacy of the internal control disclosures in our December 31, 2007 annual report (Form 10-K). Management has filed an amended December 31, 2007 annual report (Form 10-K/A (incorporated by reference)) depicting management’s assessment of internal control over financial reporting.
| • | The Company is responsible for the adequacy and accuracy of the disclosure in the filing; |
| • | 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 |
| • | The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under federal securities laws of the United States. |
Thank you in advance for your anticipated courtesy and cooperation regarding the resolution of this matter.
Sincerely,
/s/ Craig A. Waltzer
President, Director and Chief Executive Officer
