July 10, 2006

MAIL STOP 3561

via U.S. mail and facsimile

Ernest W. Letiziano, President
Signet International Holdings, Inc.
205 Worth Avenue, Suite 316
Palm Beach, Florida 33480

Re:   Signet International Holdings, Inc.
    Form SB-2 filed June 2, 2006
	File No. 333-134665

Dear Mr. Letiziano:

	We have the following comments on your filing. 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. We note that the registration statement registers the resale of
2,449,000 shares of common stock, or approximately 63% of the
3,852,000 shares of common stock outstanding.  It appears that
this
resale transaction of this amount may be, in essence, an offering
by
or on behalf of the issuer for purposes of Rule 415(a)(4) of
Regulation C under the Securities Act.  For these sales to occur
"at
the market," the provisions of Rule 415(a)(4) must be satisfied.
As
your offering does not appear to meet these provisions, an "at the
market" offering would not appear permissible.  Therefore it would
appear that the shares being offered must be sold at a fixed price
for the duration of the offering.  Please revise or provide a
detailed analysis, if you feel this position does not apply to
you.

Registration Statement Cover Page
2. Please include the name, address and telephone number of the
agent
for service.

Cover Page of the Prospectus
3. Highlight the cross-reference to the risk factors by prominent
type or in another manner.
4. Clarify on the cover page, the summary and in the business
section, that you do not have international operations.

Table of Contents
5. Please include page numbers throughout the prospectus.

Outside Back Cover Page of the Prospectus
6. Please remove from the first paragraph the statement: "or that
we
have referred you to" or explain supplementally.

Summary Information
7. Disclose that the predecessor company, 51142 Inc., was a blank
check company.
8. Please clarify the transaction(s) that resulted in your
acquiring
Signet Entertainment Corp.  The first paragraph indicates that
Signet
acquired all of the common stock of 51142 for $36,000 cash.  The
second paragraph indicates that the company (Signet International
Holdings, formerly 51142 Inc.) acquired all of the issued and
outstanding preferred and common stock of Signet Entertainment
Corp.
for a total of 3,421,000 shares of common stock and 5 million
shares
of preferred stock.  Elsewhere in the prospectus, the disclosure
indicates 2,118,000 shares of common stock were issued in the
share
exchange.  Please clarify the series of transactions and the
reason(s) for each.  Disclose the material

terms of these transactions.  Reconcile the disclosure throughout
the
prospectus.
9. We note the statement that your network "will cover major Poker
and Blackjack tournaments as well as other major high stakes
casino
games."  Please disclose whether you have entered into any
agreements
that will provide you will the ability to air these major
tournaments.  We may have further comment.
10. Explain the statement that the network will cover other major
sports events "via satellite and cable."  Will the Poker and other
casino tournaments not also be covered by satellite and cable?
11. Explain the reference to "selected global events which have a
sports and entertainment format."
12. Clarify that you have not commenced operations, that you need
additional capital to commence operations, there is no guarantee
you
will generate any revenues and that the independent accountants
have
expressed substantial doubt about the company`s ability to
continue
as a going concern.
13. We note the disclosure about how you will generate revenues.
Given the current development stage of the company, make clear
there
is no guarantee you will generate any revenues.
14. Explain what LPTV stations are.  Also, clarify whether you
have
entered into any negotiations or agreements, preliminary or
otherwise, to purchase such stations.  Lastly, remove the
statement
that "several LPTV stations broadcast in excess of 1,000,000 TV
Households."

Risk Factors
15. Remove the reference to other filings in the intro to the risk
factors.
16. Explain the reference in risk factor one to expanding or
maintaining your operations, in light of the fact that you have
not
yet commenced operations.
17. Add risk factors discussing your lack of an operating history,
the operating losses to date and the going concern.
18. Please include in the subheading of the third and fourth risk
factors the risk to the company and/or investors.
19. The subheading to risk factor two, the inability to hire and
retain key personnel, does not reflect the risk discussed in the
narrative, the dependence upon your key employee, Mr. Letiziano.
This risk is already covered in risk factor five.  Please revise
risk
factor two to specifically discuss the risk referred to in the
subheading and focus on the impact or risk to your company.
20. Explain the "Acquisition" referred to in risk factor three.
21. We note the statements in numerous risk factors that the risk
will "affect," "adversely affect," or "impact" your business.
Please
revise to remove such generic disclosure and state the specific
risk
to the company and/or investors.
22. Revise the subheading to risk factor seven to clarify that
there
is currently no public market.
23. Risk factors eight, nine and eleven are generic risks and
should
be removed.  Relocate the disclosure in risk factor eleven
relating
to penny stock to later in the prospectus.

Selling Security Holders
24. Identify the control person(s) for those selling shareholders
that are entities.
25. Please disclose how each of the selling shareholders obtained
his
or her stock.
26. Disclose any relationship between the selling shareholders.
27. Clarify whether Mr. Letiziano is a broker-dealer or affiliate
of
a broker-dealer.
28. Please disclose how you propose to reflect any changes in
selling
security holders.
29. We note the shares of Mr. Freeman included in the selling
shareholders
table.  Disclose how Mr. Freeman received these shares.  We may
have
further comment.

Plan of Distribution
30. Please disclose that the selling shareholders and any broker-
dealers that act in connection with the sale of shares may be
deemed
to be "underwriters" within the meaning of Section 2(11) of the
Securities Act, and any commissions received by such broker-
dealers
and any profit on the resale of shares sold by them while acting
as
principals might be deemed to be underwriting discounts or
commissions under the Securities Act. Also, discuss the impact of
Regulation M upon the selling shareholder offering.

Directors, Executive Officers, Promoters and Control Persons
31. Remove the promotional disclosure regarding Ringside
International Broadcast Corporation.
32. Disclose the amount and percent of time Mr. Letiziano devotes
to
your company.
33. Please revise this section, and disclosure throughout the
prospectus, to avoid references to current "officers" and
"directors," since the company has only one officer and director.
34. Please describe in greater detail Mr. Letiziano`s current work
as
an "international monetarist."

Security Ownership of Certain Beneficial Owners and Management
35. Revise the ownership table to attribute ownership of the
shares
held by spouses to the corresponding beneficial owners.  Refer to
Securities Act Release No. 33-4819 ("a person is regarded as the
beneficial owner of securities held in the name of his or her
spouse
and their minor children").
36. It appears that Signet Entertainment Corp. is controlled by
Mr.
Letiziano and should be included in the amount listed in the
beneficial ownership table.  The nature of the ownership should be
included in a footnote.
37.
Please provide the address for each beneficial owner.  The
company`s
address may only be used for officers and directors.
38. Please update the beneficial ownership table in light of the
shares issued on June 30, 2006 pursuant to exhibit 10.3.

Description of Securities
39. We note that 5 million shares of preferred stock are issued
and
outstanding.  Please revise this section to clearly indicate the
material rights of the preferred stock issued and outstanding.
Consider whether the beneficial ownership table should be revised
in
light of these rights.

Business of Issuer
40. Please state if true, that you are not a blank check company,
as
defined by Rule 419 and that you will not enter into a business
combination.
41. We note the disclosure that you issued 3,421,000 shares of
common
stock and 5 million shares of preferred stock in the stock
purchase
agreement.  Exhibit 2.2 does not refer to the 5 million shares of
preferred stock.  Please advise.
42. Disclose the material terms of the agreements with Triple Play
Media and Big Vision.  For instance, we note that the agreement
with
Triple Play was in 2002 and that at the time of the agreement
Triple
Play was "a corporation to be formed."  Also, it appears that the
agreement with Triple Play was with a significant shareholder of
SIG.
Please disclose.
43. We note that the agreement with Triple Play was entered into
on
September 23, 2002.  SIG was not incorporated until October 17,
2003.
Please explain whether there were any predecessors to SIG.  If so,
disclose the material terms as required by Item 101(a) of
Regulation
S-B.  We may have further comment.
44. Explain the reference to Triple Play providing programming
content.  The management agreement filed as exhibit 10.1 does not
provide for programming.
45. We note the $50,000 signing bonus to Mr. Grad, the guaranteed
payment of $200,000 per year to Mr. Grad, moving and relocation
costs
and other benefits.  Please disclose.
46. Explain the reference to "most favored nation" basis.
47. Disclose the material terms of the April 13, 2006 agreement
with
Freehawk Productions.
48. Most of the programming purchased from Freehawk does not
appear
to fall within the gaming and sporting industry.  Please discuss
and
explain the reason for the agreement.  We may have further
comment.
49. Provide a detailed discussion of your proposed role in the
business plan.

Programming
50. Provide the basis for your belief that "this market is capable
of
producing substantial revenue based on the commercial advertising
revenue potential of the hotel/casino/travel industry," and that
"the
sales revenues from these industries alone, after the first year,
will not only cover operating costs and expenses thereafter, but
also, within the next eighteen months, return sufficient revenue
to
pay for all of our initial capital expenditures" or remove.
51. We note references to the World Series of Poker, championship
Blackjack playoffs and other high stakes games.  Clarify whether
you
have entered into any agreements for these programs.  If not,
remove
specific references to tournaments, as these would appear to be
promotional.
52. We note the statement that Triple Play has been approached by
"two of the largest syndicators who have expressed their eagerness
to
cooperate in our airing all of its college sports events,
including
the major conference playoffs."  Disclose whether you have entered
into any negotiations or agreements with these two syndicators.
Also, provide the basis for the statement that "these games will
be
aired in North America to a minimum of twenty million households,
and
to the ninety-eight million households in Europe" or remove.  We
may
have further comment.
53. Please explain the "Swimwear Pageants" reference.  Is this a
specific program or a general term?  Disclose whether Triple Play
has
an agreement to "exclusively product" this "internationally
popular
program.
54.
Describe in detail your "network in the United States" and your
"North America, European and South America satellite delivery
systems."
55. Remove the disclosure regarding the evaluation and assessment
by
an independent appraiser of this programming.  This would appear
speculative.
56. Provide the source of the statements made regarding the
infomercial industry.
57. Please provide the basis for the statement that Big Vision
"enjoys the distinctive opportunity to produce, direct and
televise
most of the leading events in the sports and entertainment
business"
or remove.
58. Please explain how Big Vision`s affiliation with Triple Play
"assures uninterrupted local programming coverage."
59. Discuss how you plan to distribute your programming.  We note
that the LPTV stations are "another means for distributing" your
programming.
60. Provide the source of the information regarding LPTV.
61. Explain how you plan to finance the purchase of LPTV stations.
Is it likely that such purchase would result in a change in
control?
We may have further comment.
62. Provide the disclosure required by Item 101(b)(4) of
Regulation
S-B.

Low Power Television Stations
63. Disclose whether you have taken any steps to acquire LPTV
stations and, if yes, describe them in detail.

Digital Terrestrial Broadcasting Network
64. Disclose the basis for your assertions in this section.  If
applicable, support your statements by supplementally providing us
with copies of, or excerpts from, reports or publications which
you
reference.  If you do not have appropriate independent support for
a
statement, please revise the language to make clear that this is
the
belief of the registrant based on its experience in the industry,
if
true, and support such basis.

Hi-Definition Television
65. We note the reference to the proposal from a major satellite
provider.  Please disclose whether you have entered into a
definitive
agreement.  If so, disclose the material terms of the proposal and
identify the provider.  If not, disclose the current status of
negotiations.  Also, revise the last sentence in view of the fact
that you do not presently have "viewers throughout the world."

Intellectual Properties
66. Provide the disclosure required by Item 101(b)(8) and (9) of
Regulation S-B.
67. Please explain why your executive officer is not considered an
employee.  We may have further comment.

Caution Regarding Forward-Looking Information
68. We note your disclosure in the last sentence of this section.
Please explain in light of the undertakings in Item 512 of
Regulation
S-B.

Plan of Operation
69. Please provide a detailed plan of operations required by Item
303(a) of Regulation S-B, first for the next twelve months and,
then,
to the point of generating revenues.  Ensure that all milestones
necessary to take your company to generating revenues are
described,
including details on how you will accomplish your milestones.
Ensure
that you include the estimated costs associated with each
milestone
and a timeframe for each in weeks or months.  Discuss how you plan
to
pay these estimated expenses.  We may have additional comments.
70. We note the statement that Mr. Letiziano has agreed to cover
costs for operations until additional funds become available.
Please
disclose the material terms of this agreement and file as an
exhibit.
State whether this additional funding will consist of loans or
will
be a contribution to capital.  Also, clarify whether Mr. Letiziano
is
legally obligated to provide such funding.  State how the amount
to
be provided will be determined.  We may have further comment.
71. Disclose your current cash balance as of the most recent
practicable date.  Explain the statement that "completion of your
plan of operations may be subject to attaining adequate revenue
and/or raising additional funds."  Do you currently have
sufficient
cash to start implementing your plan of operations and commence
generating revenues?
72. Please discuss the components that went into your
determination
that your operational and general and administrative expenses for
the
next twelve months would be $125,000.

Capital Resources and Liquidity
73. Clarify in the second paragraph that it is the independent
auditors who have stated that there is substantial doubt about
your
ability to continue as a going concern.  Also, disclose the
reasons
they have given for this conclusion.
74. Please explain the reference to any "business acquisition or
combination transaction."  We may have further comment.

Certain Relationships and Related Transactions
75. Please disclose that Richard Grad is the CEO of Triple Play
and
discuss the related party transactions.
76. Name the promoter(s) and provide the disclosure required by
Item
404(d) of Regulation S-B

Executive Compensation
77. We note that Mr. Letiziano`s salary has been deferred until
the
company is able to pay this amount.  Please explain how this will
be
determined and who will make the determination.  Explain how Mr.
Letiziano`s salary is determined in light of the lack of an
employment agreement.

Part II

Recent Sales of Unregistered Securities
78. Discuss the basis for your reliance upon each exemption.
State
whether the investors were sophisticated and/or accredited.
Clarify
the information provided to the investors and clarify whether
general
solicitation or advertising were used in these offerings.
79. Disclose the type of consideration received in each
transaction,
and if not cash, discuss the valuation.
80. Discuss the private placements of the predecessor company for
the
past three years.
81. The May 2006 private placement involved eight investors.
Please
reconcile with the disclosure in your reliance upon Rule 506 that
there were 41 investors.  We may have further comment.

Exhibits
82. Please provide the correct incorporation by reference for
exhibit
2.2.
83. We direct your attention to Item 601(b)(3) of Regulation S-B,
which requires that each time the company files an amendment to
its
articles of incorporation, it must file a complete copy of the
articles as amended.  Please re-file the articles of
incorporation,
as amended.
84. Please file as exhibits instruments defining the rights of
security holders, in particular we note the preferred stock
outstanding.
85. File a validly executed exhibit 10.3.
86. File the lease agreement as an exhibit.
87. Please include exhibit 21 in the index of exhibits.
88. We note exhibits 99 are publicly available documents.  While
these do not appear to meet the requirements of Item 10 of
Regulation
S-B and should be removed as exhibits, please provide a legal
analysis for the potential legal liability under the federal
securities laws for such public disclosure.  We may have further
comment.

Signatures
89. Include the signature of the chief accounting officer.  See
the
"Instructions for Signatures" in Form SB-2.

Form 10-KSB for the fiscal year ended December 31, 2005
90. Please apply the above comments on the Form SB-2 to the Form
10-
KSB, as applicable.
91. Please explain why the company has checked the box that it is
not
a shell company as defined in Rule 12b-2 of the Exchange Act.  The
company only has nominal cash as its only asset.  We may have
further
comment.
92. The financial statements are part of the Form 10-KSB and
therefore should be included before the signatures.  Please
revise.
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.

    We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

?	the company may not assert staff comments and the declaration
of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

    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 Babette Cooper at (202) 551-3396 if you have
questions
regarding comments on the financial statements and related
matters.
Please contact Susann Reilly at (202) 551-3236 with other
questions.

Sincerely,



John Reynolds
Assistant Director
Office of Emerging Growth Companies

cc:  Gregg Jaclin, Esq.
By facsimile to (732) 577-1188
Ernest W. Letiziano, President
Signet International Holdings, Inc.
July 10, 2006
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