ALPHATRADE.COM
                      Suite 1322 - 1111 West Georgia Street
                       Vancouver, British Columbia, Canada
                                     V6E 4M3


                                December 8, 2005



Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

To whom it may concern:

     In connection with the our response to comments regarding our Form 8-K/A
For AlphaTrade.com (the "Company"), SEC File No. 0-25631, the Company hereby
acknowledges that:

     o   the Company is responsible for the adequacy and accuracy of the
         disclosure in the filing;

     o   staff comments or changes to disclosure in response to staff comments
         do not foreclose the Commission from taking any action with respect to
         the filing; and

     o   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 to the above, the Company is aware that the Division of
Enforcement has access to all information provided to the staff of the Division
of Corporation Finance in its review of the Company's filing or in response to
comments on the filing.

                                                     Sincerely,

                                                     ALPHATRADE.COM


                                                     By: /s/ Penny Perfect
                                                        -----------------------
                                                             Penny Perfect
                                                    Its: Chief Executive Officer