MAIL STOP 0511

									March 25, 2005

Dr. Earl Abbott
President
AAA Minerals, Inc.
3841 Amador Way
Reno, NV 89502

Re:	AAA Minerals, Inc.
      Registration Statement on Form SB-2
      File No. 333-119848
	Amended February 17, 2005

Dear Mr. Bravo:


      We have reviewed your amended 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.

Summary

1. We note that Carla Bird and Jesse M. Wall, the vendors of the
BA
property purchased acquired the claims for $10,000 in April 2004.
Please explain the Date of Recording in relations to the Purchase
Date as disclosed on page 23.



Selling Shareholders, page 14

2. According to the disclosure" none of the selling shareholders
has
had a material relationship with us other that as a shareholder at
anytime within the past three years."  We note that Carla Bird and
Jesse M. Wall are selling shareholders, therefore it would appear
that this statement should be reconciled to the disclosure
elsewhere
in the filing.

3. Please advise by supplemental letter from whom Carla Bird and
Jesse M. Wall acquired the claims from and that parties
relationship
if any to the company, officers and directors and the selling
shareholders.  We may have further comments.

Title to the BA Property, pages 22-24

4. According to the disclosure on page 22, in order to maintain
the
claims in good standing, the exploration work, or cash payments in
lieu will be due by November 2005.  Please reconcile that to the
disclosure on page 23 that the claims comprising the BA property
are
in good standing until November 14, 2006.

General

5. Your attention is directed to Item 310(g) of Regulation S-B and
the possible need for updated financial statements and related
disclosures.


6. You are reminded that a currently dated consent of the
independent
accountants with typed signature should be included in any
amendment
to the registration statement.  The consent in Exhibit 23.1 should
be
signed in the name of the firm rather than an individual partner.
Please revise.

Accountants Report

7. The report of the Chartered Accountants on page 29 should
reference "the standards of the Public Company Accounting
Oversight
Board (United States)," rather than generally accepted auditing
standards.  Please refer to PCAOB Auditing Standard No.1 and SEC
Release No. 33-8422.  Also, please include both the printed name
of
the firm and the authorized signature of the firm.  See Rule 302
of
Regulation S-T and revise accordingly.





Closing Comments

      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 Maureen Bauer at (202) 942-1824 or Tia
Jenkins
at (202) 942-1902 if you have questions regarding comments on the
financial statements and related matters.  Please contact Craig
Slivka at (202) 942-7470 with any other questions.

Sincerely,


      John Reynolds
      Assistant Director
      Emerging Growth Companies


Dr. Earl Abbott
Fax (775) 827-2324