Mail Stop 3561
								February 28, 2006

Robert C. Harris
564 Wedge Lane
Fernley, Nevada 89408

	Re: 	Cantop Corporation
		Amendment No. 1 to Registration Statement on Form SB-2
		Filed January 27, 2006
		File No. 333-128697

Dear Mr. Harris:

	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 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.

Summary, page 3
1. We note your response to comment 5 in our letter dated October
25,
2005.  Please explain in this section and in the description of
business section why the claims are being held in trust and
disclose
any risks to you of not holding the claims directly.

Summary Financial Information, page 4
2. Please correct here, on page 24 and on page F-8, the amount
presented as your net loss from inception on February 22, 2005 to
July 31, 2005.



Plan of Distribution, page 13
3. Please revise the last sentence of the second paragraph of the
added text to disclose that there can be no assurance that
increased
liquidity of the shares will result from an OTCBB listing.

Biographical Information, page 15
4. Since the statement regarding the history of John Tann Ltd, is
not
based or personal knowledge of the registrant, we suggest that
this
reference be deleted, while you retain a description of that
firm`s
business.

Description of Business, page 19

Description, Location and Access, page 20
5. You have not provided us with a copy of  Mr. Sookochoff`s
report,
as requested by comment 16 in our letter dated October 25, 2006.
Please advise.

Mineralization, page 20
6. Please tell us why you are relying on a 1963 report from the
Minister of Mines, rather than a more current one, if any such
report
is available.

Financial Statements, page 27
7. Please update the financial statements and related financial
information included in the filing, as required by Item 310(g) of
Regulation S-B.  Specifically, please present an interim balance
sheet as of your first quarter (October 31, 2005) and a statement
of
operations and cash flows for the quarter ended October 31, 2005
and
update the notes to your financial statements as necessary.
Please
also note that as an exploration stage enterprise you are required
to
present cumulative statements of operation, cash flow and
stockholders` equity since your inception to the most recent
balance
sheet date presented.  Additionally, please update your summary
financial information on page 4, plan of operation on page 24 and
any
other section of your filing, as necessary, to reflect the
revisions
from your updated interim financial statements.






Part II, page II-1

Undertakings, page II-5
8. Please include the revised form of undertakings required by
Items
512(a) and (g) of Regulation S-B.  See Release 33-8591, effective
December 1, 2005.

Exhibit 10.2
9. We note your response to comment 27 in our letter dated October
25, 2005 and note that you filed a letter from Mr. Sostad
confirming
that he holds the claims in trust for you.  Please file the trust
document.

				* * * * * * * * *

	You may contact Yon Kim at (202) 551-3323 or William Choi at
(202) 551-3716 if you have questions regarding comments on the
financial statements or related matters.  Please contact Albert
Yarashus at (202) 551-3239, Ellie Quarles, Special  Counsel, at
(202)
551-3238, or me at (202) 551-3270 with any other questions.


								Sincerely,


								H. Christopher Owings

Assistant Director

cc:  Karen Batcher
      FAX (619) 789-6262
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Robert C. Harris
Cantop Ventures, Inc.
February 28, 2006
Page 1