April 18, 2005


Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549-0306
Mail Stop 05-11
Attn: Angela J. Halac, Staff Accountant

         RE:      IMEDIA INTERNATIONAL, INC.
                  RESPONSES TO STAFF COMMENTS OF APRIL 14, 2005
                  WITH RESPECT TO:
                  CURRENT REPORT ON FORM 8-K FILED APRIL 13, 2005

Dear Ms. Halac:

         iMedia International,  Inc. (the "COMPANY"),  has enclosed a copy of an
amended  Current  Report  on Form  8-K (the  "AMENDED  REPORT")  filed  today in
response to the Staff's  Comments of April 14, 2005 (the "COMMENT  LETTER").  In
this letter, we refer to the Staff of the Securities and Exchange  Commission as
the "STAFF."

         In  addition  to filing the Amended  Report we have  enclosed  with the
paper  submission of this letter a "marked" copy of the amended  Current Report,
comparing   the   amendment  to  the  original   filing,   and  hereby   provide
supplementally  the  following  responses  in reply to the Comment  Letter.

         PLEASE  AMEND  THE  FORM  8-K  TO  STATE  WHETHER  THE  FORMER
         ACCOUNTANT RESIGNED,  DECLINED TO STAND FOR RE-ELECTION OR WAS
         DISMISSED AS REQUIRED BY ITEM 304(a)(1)(i) OF REGULATION S-B.

                  The Company has complied with the Staff's  comment in
         paragraph one of the Amended Report.

         ITEM  304(a)(1)(iv)(A)  OF  REGULATION  S-B  REQUIRES  YOU  TO
         DISCLOSE WHETHER THERE WERE DISAGREEMENTS  BETWEEN THE COMPANY
         AND THE FORMER ACCOUNTANT FOR THE TWO MOST RECENT FISCAL YEARS
         AND  ANY  SUBSEQUENT   INTERIM  PERIOD  THROUGH  THE  DATE  OF
         RESIGNATION. PLEASE REVISE ACCORDINGLY.

                  The Company has complied with the Staff's  comment in
         paragraph  three of the Amended Report by adding language that
         includes the period from the end of the Company's  last fiscal
         year  to  April  1,  2005,   the  date  of  its   accountant's
         resignation.





United States Securities and Exchange Commission
April 18, 2005
Page 2


         In  connection  with our response in this letter,  we  acknowledge  the
following:

         o        that the Company is responsible  for the adequacy and accuracy
                  of the disclosure in the Amended Report,

         o        that Staff  comments or changes to  disclosure  in response to
                  Staff comments do not foreclose the Commission from taking any
                  action with respect to the Amended Report; and

         o        that the Company may not assert Staff comments as a defense in
                  any proceeding initiated by the Commission or any person under
                  the federal securities law of the United States.

         We hope the above has been responsive to the Staff's  comments.  If you
have any questions or require any additional  information  or documents,  please
telephone me at (818) 444-4503.

                                   Sincerely,

                                   /s/ Frank Unruh
                                   -----------------------
                                   Chief Financial Officer

Enclosures


cc:      Gregory Akselrud