First Capital International, Inc.
5120 Woodway Drive, Suite 9000
Houston, Texas 77056
713-629-4866
November 14, 2005
BY FAX TO: (202) 772-9210
Securities and Exchange Commission
Division of Corporate Finance
Attn: Brad Skinner
100 F Street, N.E.
Washington, D.C. 20549
Re: First Capital International, Inc. (the "Company")
File No. 000-26271
Item 4.01, Form 8-K; filed November 3, 2005
Dear Mr. Skinner:
In response to correspondence received from your office on November 8,
2005, please be advised of the following responses made by the Company:
1. We note that the filing was due on the fourth day following the
resignation date of our former auditors Ham, Langston & Brezina, LLP.
2. A Form 8-K/A is being filed herewith to include the requested language
and confirms that during the two most recent fiscal years and the subsequent
interim period through the date of the resignation, there have been no
disagreements with the former accountants Ham, Langston & Brezina, LLP.
3. This disclosure was previously made in Form 8-K as filed with the
Commission on November 3, 2005. Please refer to the second paragraph under the
heading "New Independent Accountants" for this disclosure.
4. Please see Exhibit 16.1 to the Form 8-K/A being filed herewith.
The Company acknowledges the following:
- 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 proceedings
initiated by the Commission or any person under the federal securities laws
of the United States.
If you have any questions or need any additional information, please
contact me at your earliest convenience. I thank you in advance for your
attention to this matter.
Very truly yours,
/s/ Alex Genin
Chief Executive Office and Director