UNITED STATES
                 SECURITIES AND EXCHANGE COMMISSION
                        WASHINGTON, D.C. 20549

DIVISION OF
CORPORATION FINANCE

         Mail Stop 3561
         Via facsimile and U.S. mail

                                         July 18, 2005
Barney A. Richmond, President
A Super Deal.com, Inc.
100 Village Square Crossing, Suite 202
Palm Beach Gardens, Florida 33410
Fax: 561-207-6299

              RE: A Super Deal.com, Inc.
                  Registration Statement on Form 10-SB
                  File Number: 000-51419
                  Filed: July 7, 2005

Dear Mr. Richmond:

       We have completed a preliminary reading of your registration statement.
Disclosure indicates that on June 2, 2005, the registrant, a wholly-owned
subsidiary of eCom eCom.com, Inc. ("eCom"), issued all of its share certificates
to the shareholders of record of eCom in a "spin-off" transaction.  Refer to
disclosure on page 9 of Form 10-SB filed on July 8, 2005. In a letter of
correspondence, please provide us with a substantive legal analysis describing
your basis for effecting this issuance without the registration of such
transaction under the federal securities laws. In the interim, promptly withdraw
the Form 10-SB filed with us on July 8, 2005, You are advised that a Form 10-SB
will become effective, by operation of law, 60 days after filing. Should your
registration statement become effective in its present form, we would be
required to consider what recommendation, if any, we should make to the
Commission. You may contact Jay Ingram at (202)551-3397 with any questions.


                                            Sincerely,

                                            /s/ for John Reynolds

                                            John Reynolds
                                            Assistant Director
                                            Office of Emerging Growth Companies