Mail Stop 03-06

April 4, 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. 2 to Registration Statement on Form SB-2
      Filed March 28, 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.

Risk Factors - Page 7

If we do not obtain additional financing, our business will fail -
Page 7

1. We note your disclosure on page 7 that you have "sufficient
funds
to conduct the initial two phases of recommended exploration on
the
property estimated to cost $15,000," and your disclosure under
"Proposed Budget" on page 24 that "[t]he Phase I exploration
program
[with a total cost of $5,000] will be funded from our cash on
hand,"
and that "[t]he anticipated $10,000 cost of the Phase II program
will
be partially funded from our current cash on hand."  Please revise
your disclosure to be consistent.

Financial Statements - Page 32

General

2. We note that you restated your results for the period ended
December 31, 2003.  Please revise your financial statements to
disclose the nature of the change in previously issued financial
statements and the effect of its correction on net income and the
related per share amounts in accordance with paragraphs 36 and 37
of
APB 20 and Instruction 2.(2)(v) to Item 310(b) of Regulation S-B.
This change should also be referenced in your auditor`s report.

Report of Independent Registered Public Accounting Firm - Page 33

3. We note the reference in the fourth paragraph to the Company`s
net
loss of $17,331 since inception.  Please reconcile this amount to
the
statement of operations which discloses net loss for the period
from
February 13, 2004 (inception) to December 31, 2004 of $41,331.

Note 4. Common Stock - Page 42

4. Please revise your footnote disclosures for the years ended
December 31, 2003 and 2004 to disclose, for each stock issuance,
the
basis for determining the stock price, for example whether it was
determined by the Board of Directors, upon an arm`s-length
negotiation, upon a valuation, etc. and details of the basis for
the
accounting treatment.

* * *

      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.
April 4, 2005
Page 1