Mail Stop 3561

May 17, 2006



Geoffrey L. Greenwood, President
Yacht Finders, Inc.
2308 - C Kettner Blvd
San Diego, California  92101

     RE: Yacht Finders, Inc. ("the company")
            Amendment No. 3 to Registration Statement on
            Form SB-2
            Filed April 12, 2006
            File No. 333-121863

Dear Mr. Greenwood:

      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.

Selling Security Holders, page 11

1. We note from the company`s response letter dated April 5, 2006
that many of the selling security holders were/are a "business
acquaintance" of Mr. Dal Grauer.  In this regard, it would appear
appropriate that a notation be added to identify these individuals
and provide a note to the table accordingly.  If you do not
believe
this information is required by Item 507 of Regulation S-B, please
tell us why.


Directors, Executive Officers, Promoters and Control Persons, page
17
Certain Relationships and Related Transactions, page 30

2. We refer back to our previous comments #5 and #6 in the staff`s
letter dated October 7, 2005.  Inasmuch as Mr. Dal Grauer  was the
incorporator of Sneeoosh and Snohomish, now Yacht Finders, it
would
appear that the disclosure requirements of Item 404 of Regulation
S-B
would apply as he appears to be a promoter of the company.  Also,
please refer to Rule 405 of Regulation C regarding the definition
of
the term "promoter". Please provide the requested disclosure for
Mr.
Grauer, or in the contrary, please advise the staff why no
disclosure
is required.

Competition and Competitive Position, page 24

3. We note your statement, "[W]e plan to offer various price and
service levels of our brokering services to clients, offering them
the ability to pay for whatever service they specifically need."
As
previously requested, please provide some specificity to
substantiate
why this is an advantage over what is provided by other companies
in
this industry.
4. With respect to the last sentence of this section, "[I]n the
opinion of management, Yacht Finders can offer yacht brokerage
customers competitive pricings for their listing inventory."
Please
provide some detail to substantiate this statement or delete it.

Financial statements, F-10 to F-18

5. We note that you have appropriately included the required
audited
financial statements for the recent two fiscal years ended
December
31, 2005 and December 31, 2004 in the registration statement.
Accordingly, please remove the financial statements for the other
periods included in pages F-10 to F-18 since they are no longer
required.  Refer to Item 310(a) of Regulation S-B.


General

6. Please provide a current consent in any amendment and consider
the
updating requirements of Item 310(g) 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 provide 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.

      Please contact Raj Rajan at (202) 551-3388 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact Janice McGuirk at (202) 551-3395 with any
other questions.





      Sincerely,




John Reynolds

Assistant Director


cc:  Karen Batcher, Esq.
       Via fax   (619) 789-6262


Geoffrey L. Greenwood
Yacht Finders, Inc.
May 17, 2006
Page 1