October 16, 2006


Securities and Exchange Commission
Washington, D.C. 20549
Attn: Linda Cvrkel, Branch Chief


Re: Hangman Productions, Inc.
    Form 10-KSB for the year ended December 31, 2005
    Filed February 22, 2006
    File No. 000-50892

Dear Ms. Cvrkel:

     The following is in response to the comments  received  September 28, 2006,
related to the Company's  filing on Form 10-KSB for the year ended  December 31,
2005,  filed February 22, 2006.  Items #1 through #10 correspond to questions #1
through #10 in your letter.

     1. As stated the Company has had access to the  Officer's  telephone  lines
     and computer systems at no cost to the Company. In response to your concern
     that these expenses  should be reflected in the financial  statements,  the
     Company  will  begin to  record a charge  related  to these  expenses.  The
     Company will  allocate a  percentage  of the common  expenses  based on its
     estimate.  A  footnote  disclosure  will be  included  to  state  that  the
     allocation  method  of  expenses  has been  used and  management  will also
     provide an estimate of the expenses on a stand-alone  basis,  if materially
     different.

     The  Company  does not  believe it is  neccessary  to amend its  historical
     financial  statements  to reflect the charge for these costs,  as the costs
     are not materially significant.

     2. As noted in the Company's 10-QSB filing for the quarter ended March, 31,
     2006,  the  Company  received  $3,250 in entry  fee  revenue.  The  Company
     distributed  $3,750 in awards.  The expense  was  recorded as a General and
     Administrative  expense in the same quarter,  ended March 31, 2006.  Future
     filings will record this expense as a cost of revenue.  These expenses will
     also be disclosed in the MD&A section of future filings.

     3. The Results of  Operations  sections in future  filings  will  include a
     discussion of the changes in financial  condition and results of operations
     for each of the last two years. A discussion  regarding causes for material
     changes  from  periods to periods in specific  line items of the  financial
     statements will be included.

     4.  Comparable  discussion of material  changes in financial  condition and
     results of operations  since the end of the last fiscal year and comparable
     interim periods will be included in future filings.

     5.  Footnotes to the financial  statements in future  filings will disclose
     the  existence of the Doolin  family's  majority  control of the  Company's
     issued and outstanding common stock.

     6.  Footnotes to the  financial  statments  in future  filings will include
     disclosure  of the fair  value of  financial  instruments  for  which it is
     practicable  to estimate that value.  The methods and  assumptions  used to
     estimate the fair value will also be included.

     7. Note 2 of the Company's  financial  statments in the Form 10-KSB for the
     year ended December 31, 2005, states that he Company has accumulated losses
     from  inception  through  December  31,  2005 of $59,997  and has a working
     capital deficit.  These factors raise substantial doubt about the Company's
     ability to continue as a going concern. Future filings will add disclosures
     to include  (1) the  possible  effects of such  conditions  an events;  (2)
     management's  evaluation of the significance of those conditions and events
     and any mitigating factors; and (3) possible discontinuance of operations.

     8. The  maturity  date of the note  disclosed in Note 5 will be included in
     future filings.

     9. Future filings will include  disclosure of the terms of the  shareholder
     loan,  disclosed  in the Form 10-QSB for the quarter  ended March 31, 2006,
     including the interest rate and maturity date of the note.

     10.  The  Company  issued  750,000  shares  of  common  stock to two of the
     Company's  officers for  forgiveness  of $37,500 in accrued  salaries.  The
     Company  determined  the value of the shares  based upon the price that the
     Company  offered shares in its most recent  offering  completed in January,
     2004, of $.05 per share.

The Company acknowledges that:

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

     If you have any other  questions  or  concerns  please  contact  me at your
convenience.


Sincerely,

/S/ JAMES DOOLIN
James Doolin
President, Hangman Productions, Inc.