April 25, 2005

Via Facsimile at 310-979-8519 and U.S. Mail

Richard H. Izumi
Chief Financial Officer and Secretary
PPOL, Inc.
11661 San Vicente Blvd., Suite 901
Suite 901
Los Angeles, CA  90049

Re:	PPOL, Inc.
Information Statement Pursuant to Section 14(f) of the Securities
Exchange Act of 1934 and Rule 14f-1 thereunder
Filed April 19, 2005
File Number 5-78970

Dear Mr. Izumi:

	We have the following comments on your filing.
Security Ownership of Certain Beneficial Owners and New Management
1. We note that one of your shareholders, Leo Global Fund,
beneficially owns greater than 5% of your common stock.  Our
records
indicate, however, that Leo Global Fund has not filed beneficial
ownership reports on Schedule 13D or 13G pursuant to Sections
13(d)
and 13(g) of the Exchange Act of 1934 and Rule 13d-1 with regard
to
this ownership.  Please advise.
New Directors and Executive Officers
2. In future filings with the Commission, please ensure that the
biographical information of the directors and executive officers
of
the company complies with Item 401 of Regulation S-B.  For
example,
you should revise each new director`s biography to completely
describe his business experience for the past five years,
disclosing
the dates of experience by month and year.

Form 8-K Filed on April 4, 2005
3. We note that this document was filed pursuant to Items 1.01,
5.01
and 5.02 of Form 8-K.  In light of the disposition of certain
assets
of the issuer, it would appear that Item 2.01 and, therefore, Item
9.01 to Form 8-K are also applicable to this change of control
transaction.  Please revise to file an amended Form 8-K reflecting
these additional items and the related disclosure, or tell us why
you
believe those items are not applicable to this transaction.

Closing comment

	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.
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.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company may not assert staff comments 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 our review of your filing or in response to
our comments on your filing.

- ------
      Please respond to these comments by promptly amending the
filing and submitting a response letter filed via EDGAR and
"tagged"
as correspondence.  If the information you provide in response to
our
comments materially changes the information that you have already
provided to security holders, disseminate the revised materials in
a
manner reasonably calculated to inform them of the new
information.
If you do not agree with a comment, please tell us why in your
response.
      Please direct any questions regarding our comments to me at
(202) 551-3264.  You may also reach me via facsimile at (202) 772-
9203.

								Sincerely,



								Mara L. Ransom
								Special Counsel
								Office of Mergers and
Acquisitions

April 25, 2005
Page 1 of 2



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0303

         DIVISION OF
CORPORATION FINANCE