REVELSTOKE INDUSTRIES, INC. 14977 - 21st Avenue South Surrey, British Columbia, V4A 8G3 (604) 329-9593 November 16, 2005 Via Facsimile: 202-772-9210 Securities and Exchange Commission Division of Corporate Finance 100 F Street, N.E. Washington, D.C. 20549 Re: Revelstoke Industries, Inc. (the "Issuer") File No. 333-122862 Gentlemen: We hereby request that the effective date of the above-captioned Registration Statement be accelerated so that the same shall become effective as of 1:00 p.m. Eastern Standard time on November 18, 2005, or as soon thereafter as practicable. The Company in requesting said acceleration does hereby acknowledge: o 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; o 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 o the Company may not assert the 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. November 16, 2005 Page Two The Company also confirms that they are aware of their respective responsibilities under the Securities and Exchange Act as they relate to the proposed public offering of the securities specified in the registration statement. Very truly yours, REVELSTOKE INDUSTRIES, INC. By: /s/ Gordon C. McDougall ----------------------------------- Gordon C. McDougall, President cc: Mark A. Robertson, Esq.