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