Monster Offers
                                P.O. Box 1092
                         Bonsall, California   92003
                         Telephone:  (760) 208-4905
                         Facsimile:  (619) 374-2811

May 4, 2011

VIA EDGAR AND OVERNIGHT MAIL
----------------------------

U. S. Securities and Exchange Commission
Division of Corporate Finance
100 F. Street N.E.
Washington, DC  20549

Attention:  Maryse Mills-Apenteng, Special Counsel
            Division of Corporation Finance

RE:  Monster Offers
     Registration Statement on Form S-1 and
     Amendment No. 3 to Registration Statement on Form S-1
     Filed April 20, 2011
     File No. 333-171932

Dear Maryse Mills-Apenteng:

On behalf of Monster Offers (the "Company"), we are hereby responding to the
comment letter, dated May 4, 2011 (the "Comment Letter"), from the Staff
(the "Staff") of the U. S. Securities and Exchange Commission (the
"Commission") with respect to the Company's Registration Statement on Form
S-1 (File No. 333-171932) (the "Registration Statement").  In response to the
Comment Letter and to update certain information in the Registration
Statement, the Company is filing with the Commission today Amendment No. 4 to
the Registration Statement (the "Amendment").  We are sending you a marked
copy for your review.

For ease of reference, set forth below are the comments of the Staff with
respect to the Registration Statement.  The Company's response is set forth
below each comment.

General
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1.  We reissue prior comment 1. Your response notwithstanding, it does not
appear that you provided us with an amendment marked to show changed
material, as required by Item 310 of Regulation S-T.  Please provide a
marked copy of your next amendment on EDGAR. Please contact EDGAR filer
support at (202) 551-8900 if you require assistance.

Response:  We respectfully note the Staff's comment.  We have included a
marked copy of our amended Form S-1/A in the Correspondence template.
For your convenience, in addition to the filing on EDGAR, we will
email a copy directly to you as well as overnight a hard copy.

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2.  We note that the exhibit index no longer includes the legality opinion.
Please revise to identify in the exhibit index each required exhibit.  Note
that to the extent an exhibit was filed with a previous amendment to the Form
S-1, it will suffice to include a notation to the exhibit index indicating
that the exhibit was "previously filed."  In addition, if an exhibit is being
updated in an amendment, for example the legality opinion, references to any
previously filed versions of that exhibit need not be included in the exhibit
index.  Please revise accordingly.

Response:  We have revised the exhibit index to include the legality opinion.


Liquidity and Capital Resources, page 46
----------------------------------------

3.  Refer to prior comments 8 and 9.  It appears from your disclosure that
you do not have sufficient cash resources to fund operations, including
meeting your reporting obligations, for the next 12 months.  Please revise
your liquidity discussion to disclose the number of months your current cash
sources will fund and disclose the amount needed to fund the remaining
months.  Provide a separate risk factor specifically addressing your
liquidity position as disclosed here and stating in the risk factor
subheading the number of months of operations your current cash resources
will fund or advise.

Response:  We have revised our liquidity discussion to disclose the number of
months our current cash sources will fund and disclose the amount needed to
fund the remaining months.  We have also added a new risk factor specifically
addressing our liquidity position which discusses the number of months of
operations our current cash resources will fund. (See Risk Factor No. 5.)


We hope our responses satisfactorily address your comments.  Further, on
behalf of the company, we acknowledge that:

o  the company is responsible for the adequacy and accuracy of the disclosure
   in the filing;

o  staff comments or changes to disclosure in response to staff comments do
   not foreclose the Commission from taking any action with respect to the
   filing; and

o  the company may not assert staff comments as a defense in any proceeding
   initiated by the Commission or any person under the federal securities
   laws of the United States.

Respectfully submitted,

Monster Offers

By:  /s/  Paul Gain
--------------------------
          Paul Gain
          Director and CEO

cc:  Thomas C. Cook, Esq.
     Corporate Counsel


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