November 27, 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  November 20, 2006,
related to the Company's  filing on Form 10-KSB for the year ended  December 31,
2005, on Form 10-QSB for the period ended June 30, 2006,  and on Form 10-QSB for
the period ended September 30, 2006. Items #1 through #3 correspond to questions
#1 through #3 in your letter.

     1. 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.

     At the time the Company  issued the shares,  the Company  believed the fair
     value of the shares  was best  represented  by the  Company's  most  recent
     offering  price of $.05 per share.  As you noted in your  letter,  the more
     recent  quote on the OTC Bulletin  Board  quoted  shares at $.35 per share.
     Although a quotation was listed for the Company's  common stock, the market
     for the stock was thinly  traded and the depth of the bid was for a limited
     number of shares.  The Company  believed that a bid price of $.35 per share
     for 500 shares,  was not an accurate  representation of the true fair value
     for a substantially larger number of shares.

     2. Future  filings  will be revised to disclose  the  non-cash  item under
     supplemental cash flow information.

     3. Future filings will be revised to classify the amounts  representing the
     increase  (decrease) in loan from shareholder on a gross basis to financing
     activities.

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.