Mail Stop 3561
	November 16, 2005

Ted Burylo, President
Azzoro, Inc.
C/o Empire Stock Transfer Inc.
7251 West Lake Mead Boulevard, Suite 300
Las Vegas, NV 89128

	Re:	Azzoro, Inc.
	Amendment No. 3 to Registration Statement on Form SB-2
	Filed November 7, 2005
	File No. 333-118262

Dear Mr. Burylo:

      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
information so we may better understand your disclosure.  After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Description of Business, page 18

Geological Assessment Report: Surprise Lake Property, page 19
1. We note that in response to prior comment 2 in our letter dated
August 29, 2005, you stated in the response letter that you have
enclosed another copy of the Mr. Ostensoe`s geological report.  It
appears, however, that we are still not able to locate the
geological
report.  Please direct us to its location or provide us with a
copy
of the geological assessment report.  If you elect to furnish
another
copy of the report, please indicate in the response letter the
specific means by which you have furnished the report, e.g. via
EDGAR, mail, etc.

Results of Operations for Period Ending March 31, 2005, page 22
2. As you have included interim financial statements as of June
30,
2005, please update your disclosure to reflect your results of
operations as of June 30, 2005.

Financial Statements
3. Please revise the document to include updated interim financial
statements as of September 30, 2005 in accordance with Item 310(g)
of
Regulation S-B.

* * * *

      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 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.

	You may contact Robert Burnett, Staff Accountant, at (202)
551-
3330, or Michael Moran, Branch Chief, at (202) 551-3841, if you
have
questions regarding comments on the financial statements and
related
matters.  Please contact Kurt Murao, Attorney Advisor, at (202)
551-
3338, or David Mittelman, Legal Branch Chief, at (202) 551-3214
with
any other questions you may have.

						Sincerely,



						H. Christopher Owings
						Assistant Director


cc: 	Ted Burylo
          Fax: (604) 681-7622



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Ted Burylo
Azzoro, Inc.
November 16, 2005
Page 1