August 19, 2010



United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E., Mail Stop 7010
Washington, DC  20549

Attention:  Mr. Christopher Owings, Assistant Director

Re:     	Innovative Product Opportunities Inc. (the "Company")
	Registration Statement on Form S-1
Filed June 22, 2010
        	File Number: 333-167667

Dear Mr. Owings:

I enclose for filing under the Securities Act of 1933, as amended,  Amendment
No. 2 to the Company's Registration Statement on Form S-1 (File No.
333-167667), together with certain exhibits thereto (collectively, the
" Registration  Statement ").

The Registration Statement contains revisions that have been made in response
to comments received from the staff of the Securities and Exchange Commission
(the "Staff") in their letter dated August 12, 2010.

Set forth below is the Company's response to the Staff's comments.  The
numbering of the response corresponds to the numbering of the comment in the
letter from the Staff.

GENERAL

Comment 1

Please update your financial statements and related disclosures as necessary to
comply with Rule 8-08 of Regulation S-X at the time of effectiveness.

Response 1

The Company has revised the Registration Statement in response to this comment.


Comment 2

We note your response to comment one in our letter dated July 21, 2010.  Please
revise your registration statement to state, as you do in your response letter,
that your business plan does not include engaging in, and you have no plans to
engage in, a merger or acquisition with any other company, entity or person.

Response 2

We have revised the Registration Statement In response to this comment. Please
see page 6.




DETERMINATION OF OFFERING PRICE, PAGE 14

Comment 3

Please revise the last paragraph of this section to clarify that even if a
market maker files an application on your behalf, there is no guarantee that
the application will be accepted, your stock will become quoted, or a market
for your stock will develop.  This comment also applies to the last paragraph
of the Plan of Distribution section.  In addition, we note your statement in
the last sentence of Operating Capital and Capital Expenditures Requirements
section on Page 24 that you anticipate receiving additional capital "once (you)
are able to have (y)our securities quoted on a public exchange"; please revise
this language to clarify that your securities may never be quoted on a public
exchange.

Response 3

We have revised the Registration Statement in response to this comment. Please
see pages 14, 19 and 25.


SELLING SECURITY HOLDERS, PAGE 15

Comment 4

Please include your response to comment 13 in our letter dated July 21, 2010 in
your filing.

Response 4

We have revised the Selling Security Holder section on page 14 to state that,
"The Cellular Connection Ltd is not a broker-dealer and is not an affiliate
of a broker-dealer."


Comment 5

Please include a reference to footnote 13 in the table of selling shareholders.

Response 5

We have added the notation in the table as requested. Please see page 15.


DESCRIPTION OF BUSINESS, PAGE 19

Comment 6

We cannot locate your revised disclosure in response to comment 16 in our
letter dated July 21, 2010 regarding the extent to which you intend to
participate in the creation of products.  Please tell us where to find this
revised disclosure or revise your disclosure accordingly.

Response 6

We have revised the  Registration Statement in response to this comment. Please
see page 19.



Comment 7

Please expand your disclosure here to further describe the types of services
provided to you by selling shareholders, with a view to explaining to potential
investors at what phase you are in developing and implementing your business
plan.

Response 7

We have expanded the section on page 19 in an effort to provide potential
investors more detail about what phase we are in developing and implementing
our business plan. Please see page 19.


Comment 8

We cannot locate your revised disclosure in a response to comment 18 in our
letter dated July 21, 2010 regarding what types of products you plan to assist
in developing.  Please revise.

Response 8

We have added additional information to the end of page 19 to further detail
the types of products we plan on assisting in the development of.


CUSTOMERS, PAGE 20

Comment 9

It does not appear that you revised your disclosure in response to comment 19
in our letter dated July 21, 2010.  Please advise or revise.

Response 9

We have added additional information to the Customers section on page 20 in
response to this comment.


WHOLESALE OPERATIONS, PAGE 20

Comment 10

It does not appear that you revised your disclosure in response to comment 20
in our letter dated July 21, 2010.  Please revise your disclosure to describe
the nature of the wholesale operations that you intend to develop, including
whether you intent to sell or purchase products wholesale, the types of
products that you intend to sell or purchase, and the uses for those products.

Response 10

The Company has revised the Registration Statement in response to this comment.
Please see the "Wholesale Operations" section on page 20.




PRODUCT DEVELOPMENT, PAGE 20

Comment 11

We note your response to comment 21 in our letter dated July 21, 2010.  Please
further revise your disclosure to clarify the business in which Metro One
Development Inc. is engaged, including the types of products and/or services
that it provides to its customers and the types of products and services that
it has provided and currently provides to you.  We also note your response to
comment one in our letter dated July 21, 2010, in which you state that Metro
One Development Inc. has provided you "with the technical background knowledge
with respect to (y)our first product"; however, elsewhere you indicate that
you have not yet developed a product or retained clients. Please advise.

Response 11

The Company has revised the Registration Statement in response to this comment.
Please see the "Product Development" section on page 20.

Our response to comment 2 from your letter dated July 21, 2010 should have read
"Metro One Development Inc. has provided the Company with the technical
background knowledge with respect to our first product design." We have
revised the Registration Statement accordingly to reflect the revised
disclosure.

We have also retained Metro One Development Inc. as a client and provided them
with a new product design.


MANUFACTURING AND PRODUCT SOURCING, PAGE 21

Comment 12

We note your response to comment 22 in our letter dated July 21, 2010. Please
further revise your disclosure to clarify whether you have identified and/or
retained any suppliers and vendors.  Please also revise your disclosure to give
examples of the types of products you might need to purchase from such
suppliers and vendors; in this regard, we note that your primary business
appears to be the provision of services as apposed to products.

Response 12

We have updated the "Manufacturing and Product Sourcing" section on page 21 as
requested. We have many contacts in many industries that we rely on for
technical expertise when required. This could be a simple catalogue or in depth
engineering resources depending on the project. We do not have any agreements
in place with any potential supplier.


FINANCIAL STATEMENTS FOR THE PERIOD ENDED DECEMBER 31, 2009 AND MARCH 31, 2010

NOTE 6 - SUBSEQUENT EVENT, PAGE F11

Comment 13

Your response to comment 26 in our letter dated July 21, 2010 indicated that
you will provide the requested disclosure in your June 30, 2010 interim
financial statements.  However, comment 26 also requested that you provide us
with certain information, and this information was not included in your
response.  We therefore reissue a portion of our prior comment.  Please
explain to us whether you valued the issuances based on the fair value of
the consideration received or the fair value of the equity instruments issued,
and how you determined which of these was more reliably measurable.  If you
valued these stock issuances based on the fair value of the equity instruments
issued, please explain to us in reasonable detail how you determined the fair
value of your stock.

Response 13

The Company has revised the Registration Statement in response to this comment.
Please see the Note 3 on pages F9 and F10 for the financial statements for the
six months ended June 30, 2010.



MANAGEMENT'S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND FINANCIAL
DISCLOSURE OR PLAN OF OPERATION, PAGE 23

MANAGEMENT'S STRATEGIES VISION, PAGE 23

Comment 14

It does not appear that you revised your disclosure to fully respond to
comment 27 in our letter dated July 21, 2010.  Accordingly, we re-issue that
comment and ask that you elaborate on your overall business strategy,
including how you intend to generate revenues.  Please detail each step of
your business plan, describe the timeline for each step, indicate how much
additional capital you will require for each step and how you will acquire
such capital, and indicate how much additional capital you will require in
order to fully implement your strategic vision and how you will acquire such
capital.

Response 14

We have updated the "Business Overview" and "Management's Strategies Vision"
sections on page 23 in response to this comment.


OPERATING CAPITAL AND CAPITAL EXPENDITURE REQUIREMENTS, PAGE 24

Comment 15

We note your response to comment 30 in our letter dated July 21, 2010.
However, it does not appear that you disclosed the amounts that your chief
executive officer has committed to advance to you, including the expected
timing of receipt of such amounts and the terms of such commitments.

Response 15

We have updated the "Operating capital and Capital Expenditure Requirements"
section on page 25 as requested.


Comment 16

Please also clarify whether and how much you will require to be able to
implement your business plan if all of your cash resources will be devoted to
legal, accounting and related services.  You indicate that cash used for
other expenditures is expected to be minimal, however, we presume that you
will have expensed associated with obtaining customers and doing work for
customers.  Please revise to clarify.

Response 16

We have updated the "Operating capital and Capital Expenditure Requirements"
section on page 25 as requested.



BIOGRAPHIES OF EXECUTIVE OFFICERS AND DIRECTORS, PAGE 25

Comment 17

Please revise your disclosure to clarify the type of business in which each of
DC Design Inc. and Six Points Plastics is engaged, whether Mr. McLean has been
employed with Charbuster Inc. for at least the past five years, and the
qualifications attributes and skills of Mr. Clark that led to the conclusion
that he should serve as a director. In addition, the last sentence of
Mr. Stummer's biography is unclear; please revise to clarify its meaning.

Response 17

The Company has revised the Registration Statement in response to this comment.
Please see page 26.

We are unclear as to the Staff's position regarding our conclusion that
Mr. Clark should serve as a director.  As disclosed, Mr. Clark is the founder
of the Company,  has run a successful design and manufacturing firm for
14 years, requiring him to deal with the day to day operations of  that
company. He has also provided the necessary funds to operate the Company
and continues to do so.


DISCLOSURE OF COMMISSION POSITION OF INDEMNIFICATION FOR SECURITIES ACT
LIABILITIES,   PAGE 29

Comment 18

It does not appear that you revised your disclosure in response to comment 34
in our letter dated July 21, 2010.  Accordingly, we re-issue that comment.

Response 18

We have revised the Registration Statement in response to this comment. Please
see page 29.


DEALER PROSPECTUS DELIVERY OBLIGATION, PAGE 29

Comment 19

The second paragraph of this section should appear on the outside front cover
page of the prospectus pursuant to Item 501(b)(10) of Regulation S-K.  Please
revise accordingly.

Response 19

The Company has revised the Registration Statement in response to this comment.


UNDERTAKINGS, PAGE 31

Comment 20

It does not appear that you revised your disclosure in response to comment 37
in our letter dated July 21, 2010.  Accordingly, we re-issue that comment.

Response 20

We have revised the Registration Statement in response to this comment. Please
see pages  33 and 34.



If you have further questions or comments, please feel free to contact us or
our counsel.

We are happy to cooperate in any way we can.


Regards,

/s/ Doug Clark, CEO