AVP, INC. 6100 Center Drive, Suite 900 Los Angeles CA 90045 310-426-8000 November 1, 2005 By telecopier - 202-772-9202 Telephone - 202-551-3382 Securities and Exchange Commission Washington DC 20549 ATTN: Mat Bazley, Esq. Mail Stop 3561 Re: AVP, Inc. Registration Statement on Form SB-2 File No. 333-124084 Gentlemen: The registrant requests acceleration of the referenced registration statement to 4:00 PM, today, November 1, 2005, or as soon thereafter as possible. Very truly yours, AVP, INC. By: /s/ Andrew Reif -------------------------------- Andrew Reif, Chief Operating Officer AVP, INC. 6100 Center Drive, Suite 900 Los Angeles CA 90045 310-426-8000 November 1, 2005 By telecopier - 202-772-9202 Telephone - 202-551-3382 Securities and Exchange Commission Washington DC 20549 ATTN: Mat Bazley, Esq. Mail Stop 3561 Re: AVP, Inc. Registration Statement on Form SB-2 File No. 333-124084 Gentlemen: In connection with our request for acceleration of effectiveness of the captioned registration statement, AVP, Inc. acknowledges that: o The company is responsible for the adequacy and accuracy of the disclosure in the filings; o staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff 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. Very truly yours, AVP, INC. By: /s/ Andrew Reif --------------------------------- Andrew Reif, Chief Operating Officer