November 2, 2005



Mail Stop 6010

Christopher Miles
Wimax EU, LTD
356 Pine Avenue, Apt. 1
Pacific Grove, California 93950

Re:	Wimax EU, LTD
	Amendment No. 3 to Registration Statement on Form SB-2
	Filed October 21, 2005
	         File No. 333-123351
Dear Mr. Miles:
      We have the following comments to your filing.  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.
1. Please refer to our prior comment 11 from our letter dated
September 13, 2005 regarding your outstanding shares having
apparently exceeded your authorized shares at December 31, 2004.
It
is unclear how this does not result in you issuing shares that
were
not authorized.  Please explain.
2. Please reconcile the exercise prices of the stock options
mentioned on pages 13 and 14.

You may contact Eric Atallah at (202) 551-3663 or in his absence,
Kaitlan Tillan at (202) 551-3604, if you have questions regarding
comments on the financial statements and related matters.  Please
contact Jay Mumford at (202) 551-3637 or me at (202) 551-3617 with
any other questions.
      Sincerely,




							Russell Mancuso
							Branch Chief

cc:	Greg E. Jaclin, Esq.