MAIL STOP 7010
									June 8, 2006
John Maguire
President
Irish Mag, Inc.
646 First Avenue South
St. Petersburg, Florida 33701

RE:	Irish Mag, Inc.
	Registration Statement on Form SB-2
	File No. 333-132119
	Amended May 24, 2006

Dear Mr. Maguire:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  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.

General

1. We reissue comment 2, since you do not appear to have made the
requested change correctly.  Please give retroactive effect to the
stock split that occurred on February 15, 2006 and any other stock
splits.  This means changing your disclosures throughout the
filing,
such as the Dilution section and Recent Sales of Unregistered
Securities section, to consistently only present post-split shares
and post-split purchase price per share information for disclosing
all of your share activity.  The number of authorized, issued and
outstanding shares on your balance sheet and all amounts in your
statements of changes in stockholder`s equity also need to give
retroactive effect to the stock split.  This applies to both your
2005 and your 2004 financial statements.  Refer to SAB Topic 4:C.
For example, in your financial statements for the year ended
December
31, 2005, all common stock share amounts including the balance at
January 1, 2005 on your statement of changes in stockholder`s
equity
should already reflect the effect of the stock splits; there
should
not be a separate line item on your statement showing the
retroactive
effect of the stock splits as the effect should already be
included
in the January 1, 2005 balance.

The Offering

2. Currently, your cover page and Summary suggest that all selling
security holders will sell at a fixed price of $1.00 for the
duration
of the offering.  However, the Selling Security Holder section
suggests that only non-affiliated selling security holders may
sell
at market or privately negotiated prices once listed on the OTCBB
or
securities exchange while the Plan of Distribution implies that
all
resales can be at market or privately negotiated prices once
listed
on the OTCBB or securities exchange.  We think that you mean to
disclose that affiliated selling security holders will sell at a
fixed price of $1.00 for the duration of the offering and that
non-
affiliated selling security holders will sell at $1.00 until you
are
quoted on the OTCBB or listed on a securities exchange.
Additionally, the Selling Security Holder section discloses that
each
selling security holder is an underwriter, which contradicts the
cover page and summary where you appear to state that only
affiliated
selling security holders are underwriters.  Please revise your
disclosure throughout all relevant sections of the prospectus
accordingly.

Risk Factors

3. Please delete the "there is no assurance" language in your risk
factors since the real risk is not your inability to offer
assurance,
but rather the condition described.

Management`s Discussion and Analysis

4. Please provide a discussion and analysis of changes in your
financial condition and results of operations for the three months
ended March 31, 2006 as well as for the comparable interim period
in
the preceding year.  Refer to Item 303(b)(2) of Regulation S-B.

Closing Comments

      Please contact Nudrat Salik, Staff Accountant, at (202) 551-
3692 or Rufus Decker, Accounting Branch Chief, at (202) 3769 if
you
have questions regarding comments on the financial statements and
related matters.  Please contact Craig Slivka, Staff Attorney, at
(202) 555-3729 with any other questions.

      Sincerely,


  								Pamela A. Long
  								Assistant Director

CC:  	Diane J. Harrison, Esq.
	(727) 368-4448
John Maguire
Irish Mag, Inc.
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE