August 20, 2004


MAIL STOP 0308

Ted Burylo
Chief Executive Officer
Azzoro, Inc.
475 Howe Street, Suite 1030
Vancouver, British Columbia
Canada

	RE:	Azzoro, Inc.
		Registration Statement on Form SB-2
		File Number: 333-118262
Filed: August 16, 2004

Dear Mr. Burylo,

	We have completed a preliminary reading of your registration
statement.  It appears that your document fails in a material respect
to comply with the requirements of the Securities Act of 1933, the
rules and regulations under that Act, and the requirements of the
Form.  For this reason, we will not perform a detailed examination of
the registration statement at this time, until these material
deficiencies are addressed:

	The financial statements should be updated pursuant to Item
310(g) of Regulation S-B.  Furthermore, an audit report should also
be included in the amendment to the registration statement.

	As long as it remains in its current form, we will not recommend
acceleration of the effective date of the registration statement.
Also note that should the registration statement become effective in
its present form, we would be required to consider what
recommendation, if any, we should make to the Commission.   We
suggest that you consider submitting a substantive amendment to
correct the deficiency or a request for withdrawal of the filing.




Please understand that the purpose of our review process is to assist
you in your compliance with the applicable disclosure requirements
and to enhance the overall disclosure in your filing.  Please contact
Kurt Murao at (202) 942-1934 with any questions.  We look forward to
working with you to address these concerns.


Sincerely,



H. Christopher Owings
Assistant Director




c.c.	via - fax (604) 681-7622

Azzoro, Inc.
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