Monster Offers 8937 Quintessa Cove Street Las Vegas, NV 89148 Telephone: (702) 575-4816 May 21, 2008 VIA EDGAR TRANSMISSION - ---------------------- Mail Stop 4561 U. S. Securities and Exchange Commission Division of Corporate Finance 100 F. Street N.E. Washington, DC 20549 Attention: Mr. Hugh Fuller Re: Monster Offers Amendment No. 4 to a Form SB-2 on Form S-1/A Filed on May 6, 2008 File No. 333-148686 Dear Mr. Fuller: On behalf of Monster Offers (the "Company"), we are transmitting for filing Amendment No. 5 (the "Amendment") to the Form SB-2 Registration Statement on Form S-1/A, File No. 333-148686 (the "Registration Statement"). The Amendment is being filed in response to comments received from the Staff (the "Staff") of the U. S. Securities and Exchange Commission by telephone call to our corporate counsel on May 19, 2008, with respect to the Registration. Per your telephone request, our corporate counsel has provided an updated legal opinion letter, and we have amended the Registration Statement to reflect our most recent financials for the period ending March 31, 2008. Mr. Fuller, we want to thank you for your help and guidance throughout this comment process. We appreciate the time you have spent reviewing our Registration Statement. Respectfully yours, Monster Offers By: /s/ Nate Kaup - --------------------------------- Nate Kaup Chief Executive Officer