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                                   AZZORO INC.
                        1802 N. Carson Street, Suite 212
                               Carson City, Nevada
                              United States, 89701


December 16, 2005

U.S. Securities & Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Mail Stop 0305

Attention:   Kurt K. Murao

Dear Sirs:

Re:      Azzoro, Inc.  - Registration Statement on Form SB-2
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         Amendment No. 3 - File No. 333-118262
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Further to your letter dated November 16, 2005  concerning the  deficiencies  in
our registration statement on Form SB-2, we provide the following responses:

Description of Business, page 18
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Geological Assessment Report:  Surprise Lake Property, page 19
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1.       We note that in response to prior  comment 2 in our letter dated August
         29,  2005,  you stated in the  response  letter  that you have  enclose
         another  copy of the Mr.  Ostensoe's  geological  report.  It  appears,
         however,  that we are still not able to locate the  geological  report.
         Please  direct  us to its  location  or  provide  us with a copy of the
         geological  assessment  report. If you elect to furnish another copy of
         the report,  please  indicate in the response letter the specific means
         by which you have furnished the report, e.g. via EDGAR, mail, etc.

         We have enclosed a copy of Mr.  Ostensoe's  geological  report with our
         couriered copy of our filing.

Results of Operations for Period Ending March 31, 2005, page 22
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2.       As you have included interim financial  statements as of June 30, 2005,
         please update your  disclosure to reflect your results of operations as
         of June 30, 2005.

         We have updated our  disclosure to reflect  results of operations as of
         September 30, 2005.

<page>

Financial Statements
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3.       Please  revise  the  documents  to  include  updated interim  financial
         statements as of September 30, 2005 in accordance with Item   310(g) of
         Regulation S-B.

         We have  included  updated  financial  statements  for the period ended
         September  30, 2005 with our  amended  registration  statement  on Form
         SB-2.

         Yours truly,

         /s/ Ted Burylo

         Azzoro, Inc.
         Ted Burylo, President