L. STEPHEN ALBRIGHT
ATTORNEY AT LAW

17337 Ventura Boulevard, Suite 208
Encino, California 91316
Ph. (818) 789-0779 o Fax (818) 784-0205
LStephenAlbright@aol.com

November 28, 2005

VIA FAX, FEDERAL EXPRESS & EDGAR

Janice McGuirk, Esq.
SECURITIES & EXCHANGE COMMISSION
Division of Corporate Finance, Office of Small Business Review
450 Fifth Street N.W.
Washington, D.C. 20549

Re: FUTURA PICTURES, INC, (THE "COMPANY")
FORM SB-2 ("THIRD AMENDMENT")
ORIGINAL FILING DATE: MARCH 28, 2005, AMENDED MARCH 30, 2005 AND
JULY 15, 2005
SEC FILE NO.: 333-123611

Dear Ms. McGuirk:

I am in receipt of a copy of the Commission's August 17, 2005 comment letter to
Mr. Buddy Young of the Company. Please consider this letter to be the Company's
formal response to the Commission's latest comment letter. As required, we are
enclosing three (3) clean hard copies of the Third Amendment, with exhibits and
three (3) complete redlined copies of same, without exhibits. The redlined
copies are marked to show the changes in the format provided by Microsoft Word.
Thus, additions are highlighted in the body of the text and deletions are noted
in right margin.

We will be responding to comments in the order presented and with the same item
numbers.

PROSPECTUS COVER PAGE

Comment No. 1. The Company has clarified the "public market" where its
securities may be listed. The revision should be in compliance with the staff's
comments.

RISK FACTORS, PAGE 5

Comment No. 2. Although the Company will terminate the offering when its
securities become listed on a public market, the Company will not apply for
listing on any market until it has raised at least $300,000. Accordingly, the
Company does not believe that a "risk factor" discussing the risk of nominal
proceeds resulting from an early termination of the offering is appropriate or
necessary. Language in the Third Amendment has been revised to consistently
reflect this information. The revisions should be in compliance with the staff's
comments.

L. STEPHEN ALBRIGHT, ESQ.

Ms. Janice McGuirk
November 28, 2005
Page 2

Comment No. 3. The subheading of the fourth risk factors summarizing the risk
has been revised to respond to the staff's comments. The revisions should be in
compliance with the staff's comments.

Comment No. 4. The Company does not believe it is a "blank check company."
However, in light of recent changes in the Commission's definition of and
approach to shell companies, as a cautionary measure, the Company included the
disclosure as a risk factor. The reference has been removed from the Third
Amendment. The revision should be in compliance with the staff's comments.

USE OF PROCEEDS, PAGE 8

Comment No. 5. The undersigned, L. Stephen Albright, will not be receiving any
proceeds from the offering. The professional fees of the offering expenses will
consist primarily of auditor's fees. Other costs consist of those normally
associated with an offering such as Blue Sky costs, counsel in other states,
printing costs, filing fees and the like. The revisions should be in compliance
with the staff's comments.

MARKET FOR COMMON EQUITY, PAGE 9

Comment No. 6. The Company will not make any effort to apply for listing on a
securities market unless and until it has raised at least $300,000. Thereafter,
the Company may begin the application process for listing on either the Over the
County Bulletin Board or the Pink Sheets. The Third Amendment has been revised
to reflect this timetable. The revisions should be in compliance with the
staff's comments.

Comment No. 7. The Third Amendment has been revised to respond to the staff's
comments. The revisions should be in compliance with the staff's comments.

PLAN OF OPERATION, PAGE 17

Comments Nos. 8, 9, 11, 12 and 13. In coordination with the revisions described
in response to Comment No. 10 below, the Third Amendment has been revised to
respond to the staff's comments. The revisions should be in compliance with the
staff's comments.

Comment No. 10. The Company does not have any intent to engage in a private
placement of securities in close proximity (in time or terms) with this offering
and expose itself to a determination by the Commission that its offerings,
private and public, are integrated. Rather, any discussion by the Company that
it may be required to secure additional funds through a debt offering or other
"private placement" of securities is intended to address circumstances beyond
the scope (again, time and terms) of the Third Amendment. The Company's
discussion regarding the possibility of raising additional capital through
private placements has been revised to respond to the staff's comments. The
revisions should be in compliance with the staff's comments.

L. STEPHEN ALBRIGHT, ESQ.

Ms. Janice McGuirk
November 28, 2005
Page 3

Comment No. 14. The $100,000 promissory note is filed with the Third Amendment.
That note contains all the provisions regarding the "agreement" between the
Company and Mr. Young regarding his obligation to loan funds. Accordingly, there
is no separate "loan agreement." The revisions should be in compliance with the
staff's comments.

LIQUIDITY AND CAPITAL RESOURCES, PAGE 13

Comment No. 15. The Third Amendment has been revised to respond to the staff's
comments. The revisions should be in compliance with the staff's comments.

BUSINESS, PAGE 14

Comment No. 16. The Third Amendment has been revised to respond to the staff's
comments. The revisions should be in compliance with the staff's comments.

DESCRIPTION OF PROPERTY, PAGE 19

Comment No. 17. Please see response to Comment No. 5 above. The Third Amendment
has been revised to respond to the staff's comments. The revisions should be in
compliance with the staff's comments.

PLAN OF DISTRIBUTION, PAGE 26

Comment No. 18. The Company intends to limit the sale of shares under this
offering in the States of California, New York and New Jersey. In order to
commence the offering "promptly" after it is declared effective, the Company has
already commenced preparing applications for registration process in those
states and will work to ensure they are approved prior to the Commission
declaring the Registration Statement effective. The Third Amendment has been
revised to respond to the staff's comments. The revisions should be in
compliance with the staff's comments.

STATEMENTS OF OPERATION, PAGE F-12

Comment No. 19. The text under "Statement of Operation" has been revised to
address all of these comments. In addition, submitted with this letter please
find the Company's "supplemental schedule supporting the calculation of the
weighted average number of common shares of outstanding for all periods
presented." The revisions should be in compliance with the staff's comments.

L. STEPHEN ALBRIGHT, ESQ.

Ms. Janice McGuirk
November 28, 2005
Page 4

EXHIBIT 5

Comment No. 20. The legal opinion submitted with the Third Amendment has been
revised to respond to the staff's comments. The revisions should be in
compliance with the staff's comments.

EXHIBIT 23.1

Comment No. 20. The consent of independent accountants submitted as Exhibit 23.1
has been revised to respond to the staff's comments. The revisions should be in
compliance with the staff's comments.

CLOSING COMMENTS

Finally, there have not been any material developments since the original Form
SB-2 and therefore no "Recent Development" section has been inserted in this
Third Amendment to Form SB-2 Registration Statement.

Sincerely,

/s/ L. Stephen Albright
--------------------------
L. STEPHEN ALBRIGHT

enclosures

c: Buddy Young, w/encls

WEIGHTED AVERAGE NUMBER OF SHARES OUTSTANDING - 6 MONTH PERIOD

DATE OF DATE OF CERTIFICATE NUMBER OF DAYS DAYS IN WEIGHTED
RESOLUTION ISSUANCE # REGISTERED NAME SHARES OUTSTANDING PERIOD AVERAGE
---------- --------- ----------- ------------------ --------- ----------- ------- ---------

1/9/2005 1/9/2005 2 Young Family Trust 1,000,000 184 184 1,000,000
1/9/2005 1/9/2005 3 Joseph Adelman 10,000 184 184 10,000
1/9/2005 1/9/2005 4 Dennis Spiegelman 10,000 184 184 10,000
1/9/2005 1/9/2005 5 L. Stephen Albright 10,000 184 184 10,000
1/9/2005 1/9/2005 6 Mel Powell 10,000 184 184 10,000
1/9/2005 1/9/2005 7 Frank Capra, Jr. 10,000 184 184 10,000
1/9/2005 2/16/2005 8 Young Family Trust 190,000 184 184 190,000
2/28/2005 9 Don Tsuchiyama 5,000 184 184 5,000
2/28/2005 10 Frank Gillman 5,000 184 184 5,000

- ------------------------------------------------------------------------------------------------------------------
8/31/2005 1,250,000 1,250,000
- ------------------------------------------------------------------------------------------------------------------

2/28/2005

WEIGHTED AVERAGE NUMBER OF SHARES OUTSTANDING - SINCE INCEPTION

1/9/2005 1/9/2005 2 Young Family Trust 1,000,000 234 238 983,193
1/9/2005 1/9/2005 3 Joseph Adelman 10,000 234 238 9,832
1/9/2005 1/9/2005 4 Dennis Spiegelman 10,000 234 238 9,832
1/9/2005 1/9/2005 5 L. Stephen Albright 10,000 234 238 9,832
1/9/2005 1/9/2005 6 Mel Powell 10,000 234 238 9,832
1/9/2005 1/9/2005 7 Frank Capra, Jr. 10,000 234 238 9,832
1/9/2005 2/16/2005 8 Young Family Trust 190,000 196 238 156,471
2/28/2005 9 Don Tsuchiyama 5,000 184 238 3,866
2/28/2005 10 Frank Gillman 5,000 184 238 3,866

- ------------------------------------------------------------------------------------------------------------------
8/31/2005 1,250,000 1,196,555
- ------------------------------------------------------------------------------------------------------------------

12/10/2003
2/28/2005 446

1/5/2005 Measurement date per Comment Letter 05/03/05