Mail Stop 03-06

February 28, 2005

Brent Peters
President
High Tide Ventures, Inc.
747 17th Street, Suite 301
West Vancouver, British Columbia
Canada V7V 3T4

Re:	High Tide Ventures, Inc.
	Amendment No.1 to Registration Statement on Form SB-2
      Filed February 11, 2005
	File No. 333-121542

Dear Mr. Peters:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

      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.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Plans of Operations - Page 27

1. We reference the discussion on page 28 that the cash on hand of
$0
will only be sufficient for approximately 7 months.  Please revise
to
clarify how $0 cash will be sufficient for 7 months.  In addition,
we
note the disclosure throughout your prospectus that phase one of
your
exploration program will be funded from your cash on hand and that
phase two of your exploration program will be partially funded
from
your cash on hand.  Please revise your disclosure to clarify how
you
will fund the phase one exploration program on the Sparta
Property,
that you expect to commence in May of 2005, and partially fund the
phase two work program, that you expect to commence during July
2005,
given your current cash position.

Financial Statements

General

2. The financial statements should be updated as required by Item
310(g) of Regulation S-B.

Statement of Operations - Page F-35

3. We note from your response to prior comment 8 that your
president
provides office space to you "free of charge."  Please tell us
supplementally how much rent expense is recorded in your statement
of
operations for the years ended December 31, 2003 and 2004 in
accordance with SAB Topic 1.B.1.

4. We note from the Annual Compensation table on page 30 that no
salary was paid to Brent Peters or Douglas Smith during the years
ended December 31, 2003 or 2004.  Please tell us supplementally
how
much salary expense is recorded in your statement of operations
for
the years ended December 31, 2003 and 2004 in accordance with SAB
Topic 1.B.1.

Note 1. Nature and Continuance of Operations - Page 38

5. We note your response to prior comment 12.  As previously
requested, revise your footnote disclosures to include a detailed
discussion of the Company`s viable plan of operations, including
your
anticipated exploration funding program and expected costs,
financing
needs and sources of funding in accordance with FRC 607.02.
Provide
details of what will happen after phase II is completed.  The
specific plans to address the threat of the going concern issues
and
the plans to resolve the doubts about the entities continued
existence should also be discussed.

Note 3. Loan Payable - Page 41

6. We note your response to prior comment 14.  Please tell us
supplementally the amount of interest expense recorded for the
loan
payable during the year ended December 31, 2003 and how this is
reflected in the financial statements.

Note 4. Common Stock - Page 41

7. Please revise your footnote disclosures for the years ended
December 31, 2003 and 2004 to disclose, for each stock issuance,
the
following:

a. whether the issuances were to related parties; and

b. the basis for determining the stock price.

* * *

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Lynn Dicker at (202) 824-5264, or Brian
Cascio,
Branch Chief, at (202) 942-1791, if you have questions regarding
our
comments on the financial statements and related matters.  Please
contact Tim Buchmiller at (202) 824-5354 or me at (202) 924-7924
with
questions regarding our comments on any other part of your filing.

      Sincerely,



      David Ritenour
      Special Counsel

cc:	Karen A. Batcher, Esq. (via fax)
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Brent Peters
High Tide Ventures, Inc.
February 28, 2005
Page 3