Mail Stop 6010							April 28, 2006

Harold Schaffrick
President
Novori, Inc.
Suite 204B
9648-128th Street
Surrey, British Columbia Canada V3T 2X9

Re:	Novori, Inc
	SB-2/A filed April 10, 2006
	File No. 333-130344

 Dear Mr. Schaffrick:

      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
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.
General
1. There appears to be some redundancy in your risk factors,
particularly in risk factors 3 and 11-14, which relate to market
risks. Please delete risk factor 3 as it overlaps with risk factor
14
and also because it may confuse investors through its implication
that there is a market for your stock and a following among market
analysts for that stock.  If you believe that risk factor 3
contains
information that is not repeated in risk factor 14, then
consolidate
this information into risk factor 14.  In addition, since risk
factor
11 clearly discloses that there is no market for your securities,
this risk factor should be the first of these market -related risk
factors to be presented.

Consolidated Financial Statements

1. Please provide updated financial statements and financial
information throughout the filing pursuant to Rule 310(g) of
Regulation S-B.

Note 4.  Related Party Transactions, page F-10

2. We note your response to comment 16.  Please disclose how you
determined the fair value of the donated equipment and the office
space rent.

      As appropriate, please amend your filing 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 file your cover letter on
EDGAR under the form type label CORRESP. Please understand that we
may have additional comments after reviewing your amendment and
responses to our comments.

	We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.
*****

You may contact Dana Hartz at (202) 551-3648 or Joseph Roesler, at
(202) 551-3628 if you have questions regarding comments on the
financial statements and related matters. Please contact Zafar
Hasan
at (202) 551-3653 or me at (202) 551-3715 with any other
questions.
      Sincerely,




      Jeffrey Riedler
   Assistant Director

   cc:	Penny Green
   	Bacchus Law Group
   	1511 West 40th Avenue
   	Vancouver, British Columbia V6M 1V7
   	F: 604-408-5177