Mail Stop 3720


      January 31, 2007


Matthew Jones, President
InfoLinx Communications Ltd.
180 Pemberton Avenue
North Vancouver, BC, Canada V7P 2R5

      Re:	InfoLinx Communications Ltd.
      Registration Statement on Form SB-2
      Filed January 4, 2007
		File No. 333-139805

Dear Mr. Jones:

      We have limited our review of your filing to those issues we
have addressed in our 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 information so we may better understand
your
disclosure.  After reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.












General

1. Since you are registering all of your outstanding common stock
on
this Form SB-2, please provide us with your legal analysis as to
why
the transactions covered by the registration statement should be
regarded as a secondary offering that is eligible to be made on a
shelf basis under Rule 415(a)(1)(i) rather than a primary
offering,
i.e., the selling shareholders are actually underwriters selling
on
behalf of the issuer.  See Telephone Interpretation D-29 in our
manual of publicly available telephone interpretations, available
on
our website at
http://www.sec.gov/interps/telephone/phonesupplement1.htm, for
guidance in distinguishing secondary offerings from primary
offerings.
2. Your disclosure indicates that the selling shareholders will
sell
their shares at the "prevailing market price" or "a price
privately
determined by the shareholder and purchaser" yet there is
currently
no market for your securities other than a limited "Pink Sheet"
market for your securities.  Item 501 of Regulation S-B requires
that
you include the price range or the formula or method to be used to
calculate the offering price.  Please include a fixed price or
price
range pursuant to Rule 430A under the Securities Act prior to
effectiveness.  Also revise to state that the selling shareholders
will sell at a price of $x.xx (or a range) per share until your
shares are quoted on the OTC Bulletin Board and thereafter they
will
sell at prevailing market prices or privately-negotiated prices.
Alternatively, you may file a post-effective amendment to switch
to a
market price when the shares are quoted on the OTC Bulletin Board.
3. Please update your financial statements and related disclosure
to
meet the requirements of Form SB-2, including Item 310(g) of
Regulation S-B.  Also revise to include executive compensation and
certain relationships and related transactions disclosure for the
fiscal year ended November 30, 2006, in compliance with recently-
amended Regulation S-B Items 402 and 404.
Selling Security Holders, page 10
4. Please disclose the natural person(s) who exercise investment
and/or voting control over the shares held by each entity or non-
natural person, including, but not limited to, Axion Developments
and
Jecar Investments Ltd., listed as a selling security holder, to
the
extent they are not widely held.  See telephone interpretation 4S
under "Regulation S-K" in our March 1999 supplement to our manual
of
publicly available telephone interpretations.  In addition, you
should delete Cede & Co. from your table, and instead identify the
selling shareholders that hold their securities through Cede.





*	*	*

      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 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 filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment 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 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 Robert F. Bartelmes at (202) 551-3354 or me
at
(202) 551-3833 if you have any questions.


      					Sincerely,



      					Michele Anderson
      Legal Branch Chief


cc:  	via facsimile (949) 660-9010





Mr. Matthew Jones
InfoLinx Communications Ltd.
January 31, 2007
Page 4



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

         DIVISION OF
CORPORATION FINANCE