[GRAPHIC OMITED]
AMP PRODUCTIONS, LTD.
500-666 Burrard Street
Vancouver, B.C.  V6C 2X8
tel: (604)639-3178   fax: (604)639-3196


                                                                January 31, 2005


VIA  EDGAR  &  COURIER
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Max  A.  Webb
Assistant  Director  Office  of  Small  Business
Securities  and  Exchange  Commission
Division  of  Corporation  Finance
450  Fifth  Street,  N.W.
Washington,  D.C.  20549

     Re:  AMP  PRODUCTIONS,  LTD.
          REGISTRATION  STATEMENT  ON  FORM  SB-2
          AMENDMENT  NO.  1,  FILED  DECEMBER  21,  2004
          FILE  NO.  333-121503

Dear  Mr.  Webb:

     In connection with the above-captioned filing, we are filing with the
Commission, via Edgar, the following documents relating to the registration of
Common Stock:

A.     Pre-Effective Amendment No. 2 to our Registration Statement on Form SB-2
(the "Registration Statement"); and

B.     A copy of the Registration Statement that has been marked to indicate the
changes to the Registration Statement made by Pre-Effective Amendment No. 2.

     The Registration Statement has been amended to respond to the Staff's
letter of non-accounting comments dated, January 27, 2005.  Our responses to the
Staff's comments are set forth below in the following paragraphs numbered to
correspond to the comments in the Staff's letter.  Any capitalized terms used in
this letter shall have the meanings ascribed to them in the Registration
Statement.

PROSPECTUS  SUMMARY,  PAGE  3
- -----------------------------

1.     In  response  to  the  Staff's  comment,  we  have  added  dislosure "Our
Business"  subsection  of the Description of Business to discuss our approach to
selecting  screenplays  (pages  11  and  21  of  the  Prospectus).

RISK  FACTORS,  PAGE  6
- -----------------------

2.     In  response  to the Staff's comment, we have added a revised risk factor
titled  "We  will  not  return  your  investment"  (page  6  of the Prospectus).

MANAGEMENT'S  DISCUSSION  AND  ANALYSIS  OR  PLAN  OF  OPERATION,  PAGE  12
- ---------------------------------------------------------------------------

3.     In  response  to  the  Staff's  comment,  we  advise that we have added a
paragraph  to our disclosure that discusses script fees in Vancouver (page 11 of
the  Prospectus).

     Should  the  Staff need additional information or have questions concerning
our  response,  please  do  not  hesitate  to  contact  us.

Yours  very  truly,



/s/Thomas Mills
Thomas  E.  Mills
President  &  CEO

Enclosures