Mail Stop 3561

December 8, 2005

Connie Linder, President
Panorama Investments Corp.
Suite 720 -999 West Broadway
Vancouver, British Columbia, Canada V5Z 1K5

       RE:  Panorama Investments Corp.  ("the company")
               Amendment No. 1 to Registration Statement on
               Form 10-SB
               Filed September 20, 2005
               File No.  0-51414

Dear Ms. Linder:

We have reviewed your amended 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.

Part I.

Item 1.  Description of Business
Business Overview, page 4

Explain how the company plans to obtain "exclusive rights" to some
of
the products it plans to sell.






Connie Linder
Panorama Investments Corp.
December 8, 2005
Page 2.


Briefly describe the "Glambelt", "a niche product for the fashion
industry."

We note the disclosure that the company purchased the "Glambelt"
and
jewelry from several designers.  Please revise the disclosure to
provide some detail with respect to the jewelry items purchased.

 We further note that although the company does not have an
exclusive
contract, the designers "have produced them for us and have not
sold
them to anyone else."   Please disclose the basis for the
company`s
belief in that regard.

Product Line, page 5

Explain how the company intends to utilize Ms. Tan`s contacts
"around
the globe" to supply the company with items for its inventory.  We
note that Ms. Tan has been devoting one (1) hour per week to the
business.  Will she be in charge of ordering inventory for the
company?

Clarify your reference to "the combination of materials and styles
with modern form and functionality".

Identify the supplier of "lush fabrics".  Disclose whether or not
the
company has entered into a contract with this entity.  If so,
please
describe the terms of the arrangement and file the executed
agreement
as an exhibit to the registration statement as required by Item
601(b) of Regulation S-B.

Clarify "in association with A4SANILY".   What is the arrangement
between the company and this entity?

Please expand this section to fully describe the Vancouver Night
Market and the New York designers market.  Who sets up and watches
the company`s stall or space?  How often has the company been
represented?  What have been the results to date?

We note that the company has "submitted" its website to several
search engines named.  Please update to provide the current
status.

It is noted here and also under "Advertising" that the company
refers
to when it  launches its marketing campaign.  Previously under the
section "Results of Operations", the company referred to
"aggressive
marketing campaign in summer, 2005."  Please clarify where
appropriate, the status of this marketing campaign and discuss
what
is involved and who is conducting this marketing effort.

Tell us the basis for your statement, "...our belief that within
the
next 12 months our internet sales will comprise 80% to 90% of our
total sales." or delete it.
Connie Linder
Panorama Investments Corp.
December 8, 2005
Page 3.


Advertising, page 8

We note several references in the filing to Metohos magazine, "the
official magazine of Olympic Airlines".  Please disclose the
significance of this to the company.

Competitive Business Conditions..., page 8

With respect to the second group you refer to here, please provide
examples of where these small specialty stores are located.  In
airports, for example?

The disclosure in the last three paragraphs appears to be
promotional
or that it reflects the opinion of management.  Please delete the
promotional tone and disclose only facts that can be
substantiated.

Effect of Existing or Probable Government..., page 9

With regard to Colony One On-Line, please add the last statement
from
your response #17 in the company`s letter dated September  , 2005.

Employees, page 10

State whether or not the commission-based employee that was
recently
hired has had any relationship or affiliation with the company or
management.  If so, please identify the employee and disclose the
relationship.

Plan of Operations/ Milestones, page 12

For each milestone listed 1 through 11, please provide a more
detailed discussion of how and what was actually accomplished.

Considering the fact that none of the employees of the company has
any direct prior experience in marketing, retailing, and internet
sales, please fully explain how the milestones listed to be
accomplished during the period of September through December,
2005,
will be successfully done by the company.  Also describe in detail
what will be done.  For example, please discuss the market survey
and
discuss the plans for the "public advertising campaign".







Connie Linder
Panorama Investments Corp.
December 8, 2005
Page 4.


Risk Factors

"The Loss of our key personnel would have an adverse impact..."
,page
16

It is not clear how this would be a material risk to the company
inasmuch as management does not have any direct, prior experience
in
this line of business.  Please advise or delete.

Item 5.  Directors and Executive Officers...

Background of Officers and Directors, page 17

We note in the biographical information for Ms. Linder, Mr.
Bekropoulos, and Ms. Tan that each "intends to devote time as
required to the business of the Company".  Please explain and
disclose more specific information with respect to the hours that
are
or will be need to be devoted to the development and running of
the
business.

Part III.

Exhibits

Your index reflects that the exhibits listed are "included".
Please
revise to state by footnote when each was filed.  For example,
state
if the exhibit was filed with the initial filing of the
registration
statement or filed as part of amendment no. 1, which was filed on
September 20, 2005.

General

Please update the information throughout the filing to the latest
date practicable.


Closing Comments

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.  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


Connie Linder
Panorama Investments Corp.
December 8, 2005
Page 5.


* 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 in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; 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 filing or in response to
our comments on your filing.

 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.

You may contact Carlton Tartar at (202) 551-3387 if you have any
questions regarding the financial statements and related matters.
Please contact Janice McGuirk at (202) 551-3395 with any other
questions.




Sincerely,




John Reynolds

Assistant Director