June 3, 2005


Mail Stop 4561

VIA U.S. MAIL AND FAX (212) 223-7419

Mr. Robert K. MacLean
President and Chief Executive Officer
Internetstudios.com, Inc.
322 East 50th Street
New York, NY  10022

      Re:	Internetstudios.com, Inc.
      Form 10-KSB for the year ended December 31, 2004
      Filed May 19, 2005
      File No. 000-27363

Dear Mr. MacLean:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  In our comments, we 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.

Form 10-KSB for the year ended December 31, 2004

Financial Statements and Notes

Note 4 - Acquisition of Trocadero Library, page 30

1. Please provide us with your basis for concluding that shares
issued to Mr. Bigle were solely consideration for the assets to be
acquired rather than compensation for future services under the
written management agreement disclosed on page 4.  In your
response,
explain any conditions under which the shares are forfeitable.


Note 5 - Loans Payable, page 30

2. It appears from your disclosure that the loans issued in 2003
are
convertible at a discount to the fair market value of the stock
(at
least 15%).  Please advise us how you considered EITF 98-5 and 00-
27
in accounting for these beneficial conversion features.

Note 7, Capital Stock, page 32

3. We note that you have an obligation to issue shares of common
stock in connection with the settlement of certain liabilities and
that you record this obligation as part of stockholders` equity.
Please explain to us your basis in accounting for including each
of
your obligations as a component of stockholders` equity rather
than a
liability.  Please cite the relevant accounting literature you
rely
on to support your accounting policy.  In the case of your August
and
October 2003 obligation, please explain to us why there is such a
significant delay in share issuance.

Note 9, Write-off of Accounts Payable, page 34

4. In a supplemental response, please explain in sufficient detail
the nature of these liabilities and your basis for recognizing
this
as a gain on debt extinguishment.  Also, tell us how you
considered
the applicable state escheat laws when making the determination
that
this is a gain on debt extinguishment rather than unclaimed
property.
Refer also to paragraph 16 of SFAS 140.

5. Please tell us what monetary or non-monetary consideration you
gave up to settle amounts payable to your current and former
officers
and how you accounted for such consideration.  If no consideration
was transferred, please explain to us in sufficient detail why
your
current and former officers would forgive this debt.  Finally,
explain how you considered footnote 1 of APB 26 in recognizing a
gain
on this transaction.


*  *  *  *

	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 the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

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

* the company is responsible for the adequacy and accuracy of the
disclosure 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 filings; and

* the company 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.

	You may contact Josh Forgione, at (202) 551-3431, or me, at
(202) 551-3403, if you have questions. Please respond to the
comments
included in this letter within ten business days or tell us when
you
will provide us with a response.  Please file your response on
EDGAR.

								Sincerely,



      Steven Jacobs
      Accounting Branch Chief

??

??

??

??

Mr. Robert K. MacLean
Internetstudios.com, Inc.
June 3, 2005
Page 1