ROBERTSON & WILLIAMS
Attorneys and Counselors At Law
3033 N.W. 63rd Street, Suite 200
Oklahoma City, Oklahoma 73116-3607
(405) 848-1944 . Fax (405) 843-6707
November 16, 2005
Mark P. Shuman
Branch Chief - Legal
Securities and Exchange Commission
Washington, D.C. 20549
Re: Revelstoke Industries, Inc.
Amendment No. 4 to Registration Statement filed November 16, 2005
File No. 333-122862
Dear Mr. Shuman:
Transmitted herewith for electronic filing with the Securities and Exchange
Commission (the "Commission") is one complete copy of Amendment No. 4
("Amendment No. 4") to the Form SB-2 Registration Statement of Revelstoke
Industries, Inc. (the "Company"), File No. 333-122862, including exhibits,
signed in accordance with the regulations and marked to show the changes from
the Amendment No. 3 to the Registration Statement as filed with the Commission
on October 24, 2005.
In response to your comment letter dated November 15, 2005, we have the
following responses. The numbered responses correspond to your comments, taken
in numerical order.
Prospectus Cover Page
- ---------------------
Comment No. 1 The Cover Page of the Prospectus has been revised to include
the information required under Item 501(a)(9)(iii) of
Regulation SB. We have also put the same disclosure language
concerning no minimum purchase requirements under the Plan
of Distribution.
Signatures
- ----------
Comment No. 2 We have added appropriate identification that Mr. McDougall
is also the Principal Accounting Officer for the Company.
We made some additional date changes in the prospectus to
reflect a more current date for some of the information
provided. Such changes are appropriately marked.
If you have any questions regarding and of the information set forth
herein, please do not hesitate to contact the undersigned at 405-848-1944.
Very truly yours,
/s/ Mark A. Robertson
----------------------------
Mark A. Robertson
For the Firm
MAR:dl
cc: Gordon McDougall
Glen Wallace