Mail Stop 3561

January 12, 2006

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. 2 to Registration Statement on
               Form 10-SB
               Filed December 15, 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.

Sales and Marketing, page 7

1. In the penultimate paragraph of this section, please make clear
that with respect to the statement  "[W]e anticipate this will
change
dramatically over the next twelve months as we generate brand
recognition and are able to launch our marketing campaign" That
there
is no assurance that such result will occur or when such a result
might occur.









Advertising, page 8

2.	With respect to the sentence, "...we plan to launch an
advertising campaign during March, 2006 by placing ads in trade
magazines...", please add if true that this will include "Metohos"
magazine.

3.	If the company does execute an agreement with "Metohos"
magazine,  please outline the material provisions and file the
agreement as an exhibit to the registration statement as required
by
Item 601(b) of Regulation S-B.

Closing Comments

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