Mail Stop 3561
                                                              July
7,
2005

Scott D. McDowell, President
Bulldog Financial, Inc.
98 South Holman Way
Golden, CO  80401

RE:  Bulldog Financial, Inc.  ("the company")
        File No.  333-120689
        Amendment No. 2 to Form SB-2
        Filed June 3, 2005

Dear Mr. McDowell:

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.

Business, page 17

As previously requested, please name the sources of the
information
and file their consents.  If the consents are not required to be
filed under Federal law or regulations, please advise.

Financial Statements

Please file an updated consent of the independent accountant as an
exhibit to your next amendment.  Also, please note the financial
statement updating requirements of Item 310 of Regulation S-B.


Closing Comments

We will consider a written request for acceleration of the
effective
date of the registration statement as a confirmation of the fact
that
those requesting acceleration are aware of their respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

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.

Please contact Janice McGuirk at (202) 551-3395 with any
questions.




Sincerely,





John Reynolds, Assistant Director

Office of Emerging Growth Companies


CC:   Conrad C. Lysiak, Esq.
          Via fax (509) 747-1770







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