[OMNICITY CORP. LOGO]


October 29, 2010

                                                    VIA EDGAR CORRESPONDENCE AND
                                                        DELIVERED MAIL STOP 3720

United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C.
United States of America  20549

Attention: Mr. Larry Spirgel, Assistant Director

Dear Sirs/Mesdames:

                                 Omnicity Corp.
                Form 10-K for the Fiscal Year Ended July 31, 2009
                            Filed on October 23, 2009
            Form 10-Q for the Quarterly Period Ended October 31, 2009
                           Filed on December 21, 2009
                               File No. 000-52827

We  acknowledge  receipt of your letter  addressed to the Company on October 21,
2010.

Commission Comment:

Form 10-K/A for the Fiscal Year Ended July 31, 2009

Report of Independent Registered Public Accounting Firm, Page 28

1.   We note your  response to prior  comments  one and five from your  response
     letter  dated April 8, 2010.  Your Form 10-K/A does not have the dual dated
     audit report as you discussed in your  response.  Please  request that your
     auditors revise accordingly.

Company Response:

     We confirm that the Company's current  auditors,  Weaver & Martin LLC, have
provided a dual dated audit report as at March 15, 2010.  The  revisions to this
audit report can be found on page 28 of the enclosed  redlined 10-K/A (Amendment
No. 2).

Commission Comment:

Consolidated Statements of Operations, page 31

2.   Please amend to disclose the weighted  average  shares  outstanding  on the
     face of your  consolidated  statement of  operations.  In addition,  please
     provide  footnote  disclosure  showing how you calculated basic and diluted
     earnings per share in accordance with ASC 260.  Similarly revise all future
     filings to include these disclosures.

Company Response:

     We confirm that our  consolidated  statement of operations now includes the
weighted  average  shares  outstanding  and footnote  disclosure  has been added
showing how we  calculated  basic and diluted  earnings per share in  accordance
with ASC 260. All future filings will include these disclosures.

Commission Comment:

Form 10-Q/A for the quarterly period ended October 31, 2009

Item 4. Controls and Procedures, page 20

3.   Since you had a material restatement for the quarterly period ended October
     31, 2009 tell us why you believe your  disclosure  controls and  procedures
     are effective or revise accordingly.

Company Response:

     We confirm that we have revised Item 4. Controls and  Procedures to include
disclosure that our controls and procedures are not effective.

We sincerely hope and trust that the foregoing is clear and satisfactory in this
matter.  Should the Commission  have any further  comments or questions  arising
from any of the same please do not  hesitate to contact me at (604)  646-1563 at
any time.

We thank the Commission for its prompt  attention to and ongoing  cooperation in
this matter, and we remain,

Yours very truly,


"Don Prest"
- -------------------------
Don Prest, CFO
Omnicity Corp.