Mail Stop 3-5						March 3, 2005

Via Fax and US Mail

Mr. Steven Gaspar
President
VMH Videomoviehouse.Com, Inc.
14-34368 Manufacturer`s Way
Abbotsford, British Columbia, Canada V2S 7MI

RE: 	VMH Videomovihouse.Com, Inc.
	Form 10-KSB for the Year Ended June Ended June 30, 2004
Form 10-QSB for the Quarterly Periods Ended September 30, 2004 and
December 31, 2004
File Number 333-70836

Dear Mr. Gaspar:

	We have reviewed the above referenced filings and have the
following comments.  We have limited our review to the financial
statements and related disclosures.  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 filings.

	Where expanded or revised disclosure is requested, you may
comply with these comments in future filings.  If you disagree, we
will consider your explanation as to why our comments are
inapplicable or a revision is unnecessary.  In some of our
comments,
we may ask you to provide us with additional information so we may
better understand your disclosure.  Please be as detailed as
necessary in your explanations.  We look forward to working with
you
in these respects and welcome any question you may have about any
aspects of our review.




Form 10-KSB for the Year Ended June 30, 2004

Notes to Financial Statements
Note 2 - Summary of Significant Accounting Policies, page F-6

1. Please disclose your accounting for officers` salaries that
have
been deferred as disclosed on page 11.

Note 6 - Revenue and Cost recognition, page 13

2. Expand your disclosure to clearly explain the sub-distributor
relationship with Amazon.com and Half.com and your accounting
related
to this relationship.  Additionally, disclose your revenue
recognition policy with regard to sales made by or through these
third parties.   Refer to EITF No. 99-19 for guidance.

3. Please disclose if any consideration is given by you to these
third parties in making these sales and your accounting for this
consideration.  Refer to EITF No. 01-09 for guidance.

4. Please disclose your accounting for the money back guarantee
that
is disclosed on page 4.

5. Please disclose your accounting for any "charge backs" issued
by
credit card processors for sales paid by credit card that are
uncollected by the processors.

Form 10-QSB for the Quarterly Period Ended December 31, 2004

Statement of Operations, page F-2

6. Please disclose what revenues are net of and the amounts
thereof,
to the extent material.

Management`s Discussion and Analysis ...
Results of Operations, page 9

7. Please explain to us and disclose why sales have increased
significantly when compared to the corresponding prior year period
and in each quarter beginning with the quarter ended June 30,
2004.

8. We note that gross profit margins have varied significantly in
each quarter since the quarter ended June 30, 2004.  Please
explain
to us and disclose the factors that impact the margins and that
are
the cause for their variances over this time.  Also, explain why
the
margins in these quarters are significantly less than the margin
for
the quarter ended June 30, 2004.

		We urge all persons who are responsible for the accuracy
and adequacy of the disclosure in the filings reviewed by the
staff
to be certain that they have provided all information investors
require for an informed decision.  Since you are in possession of
all
facts relating to your disclosures, you are responsible for the
accuracy and adequacy of the disclosures you have made.

	In connection with responding to our comments, please
provide,
in writing, a statement acknowledging that:

* you are responsible for the adequacy and accuracy of the
disclosures in the filings;
* 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
* you may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal
securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

	Please file your response to our comments via EDGAR within
fifteen business days from the date of this letter.  Please
understand that we may have additional comments after reviewing
your
response.  You may contact Doug Jones at 202-824-5368 or the
undersigned at 202-942-1907 with any questions.

							Sincerely,



							Michael Fay
							Branch Chief

cc: via facsimile
	Mr. Steven Gaspar
	604-852-1532
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Mr. Steven Gaspar
VMH Videomoviehouse.Com, Inc.
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