ASPEN RACING STABLES, INC.
                             211 Misty Morning Drive
                            Calgary, Alberta T3Z 2Z8


                                  June 7, 2007

VIA EDGAR

Securities and Exchange Commission
100 F Street, NW
Washington, DC  20539
Attention: John Stickel, Mail Stop 3561

         Re:      Aspen Racing Stables, Inc. -  Form SB-2
                  Registration Statement No. 333-141384

To the Commission:

     Pursuant  to Rule  461 of the  General  Rules  and  Regulations  under  the
Securities Act of 1933, as amended,  Aspen Racing Stables,  Inc. (the "Company")
hereby   respectfully   requests  that  the   effectiveness   of  the  captioned
Registration Statement be accelerated to 3:00 p.m. (Washington, DC time) on June
11, 2007, or as soon thereafter as practicable.

     The Company hereby acknowledges that (i) should the Securities and Exchange
Commission  (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;  (ii) the action of the
Commission or the staff,  acting pursuant to delegated  authority,  in declaring
the  filing   effective,   does  not  relieve  the  registrant   from  its  full
responsibility  for the adequacy and accuracy of the  disclosure  in the filing;
and (iii) the Company may not assert this action as a defense in any  proceeding
initiated by the Commission or any person under the federal  securities  laws of
the United States.


                                      Sincerely,

                                      ASPEN RACING STABLES, INC.

                                      By:  /s/ Dwight McLellan
                                           -------------------------------------
                                           Dwight McLellan, Chairman, President,
                                           Chief Executive Officer