UPLOAD: SEC-generated letter

November 22, 2004


via U.S. mail and facsimile

Paul G. Carter
President and Chief Executive Officer
Custom Branded Networks, Inc.
821 E. 29th
North Vancouver, British Columbia
V7K 1B6 Canada

Re: Custom Branded Networks, Inc.
Preliminary Information Statement on Schedule 14A
File No. 0-28543
Filed November 1, 2004

Dear Mr. Carter:

We have conducted a limited review of your Schedule 14A and have
the following comments. Where indicated, we think you should revise
your document in response to these comments. If you disagree, we
will consider your explanation as to why our comment is inapplicable
or a revision is unnecessary. Please be as detailed as necessary in
your explanation. In some of our comments, we may ask you to provide
us with supplemental information so we may better understand your
disclosure. After reviewing this information, we may or may not
raise additional comments.

Please understand that the purpose of our review process is to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other aspect
of our review. Feel free to call us at the telephone numbers listed
at the end of this letter.

Preliminary 14A

1. It is not clear whether you have, in fact, identified a "resource
based project with substantial proven reserves." If you have,
provide all disclosure required information by Item 11 and 14 of
Schedule 14A.



2. Revise to clarify whether Custom Branded ever operated as turnkey
private label Internet solutions business. The first sentence of the
proposal sates that the company "has been in the business providing"
Internet solutions. However, the second paragraph states that the
business did not develop. Please revise to clarify your operations
as a turnkey private label Internet business.

3. We note your disclosure that if the number of authorized shares is
increased you will have sufficient shares to complete the
transactions. Revise to indicate whether the transaction can be
completed if Proposal I is not passed. If the property may be
purchased without the increase, revise to explain how.

4. Revise to indicate how many shares are expected to be outstanding
after the purchase.

5. Please define what a "resource based" project is and your role in
the project. Please also discuss management`s experience with other
similar "resource based" projects. Given your apparent lack of
experience in resource based operations, address why you believe that
you will be able to locate a "resource based project with substantial
proven reserves." (Emphasis added.)

6. Provide a basis for your claim that the project has substantial
proven reserves. Within this response, define "substantial" and
"proven."

7. Address, and if possible quantify, the dilution the acquisition of
the "resource based project" will have on the total voting power on
existing shareholders.

8. We note your disclosure that an increase in the number of shares
authorized is warranted because it "may" result in building a core of
income-producing assets. Revise to indicate any risks associated
with this acquisition and the reasons for doubting that this
acquisition will lead to revenue production.

9. Revise to clarify the number of preferred shares that are
currently authorized to be issued.

Proposal II

10. Please provide the actual changes to the Articles that
shareholders will be voting on. The Articles number, old language
and new language should be disclosed.

11. Provide a more complete explanation as to how a new name will be
chosen and how long it is expected to take to determine the new name.

12. Revise to clarify whether shareholders will get an opportunity to
vote on the new name when the name is chosen.



Closing Comments

As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide us
with a response. You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information. Detailed cover
letters greatly facilitate our review. Please understand that we may
have additional comments after reviewing your amendment and responses
to our comments.

We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to be
certain that they have provided all information investors require for
an informed decision. Since the company and its management are in
possession of all facts relating to a company`s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they
have made.

In connection with responding to our comments, please file a written
statement on EDGAR acknowledging that:

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

* 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

* 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.

In addition, please be advised that the Division of Enforcement has
access to all information you provide to the staff of the Division of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

Direct any questions regarding this matter to Michael McCoy at (202)
942-1908 or, in his absence, to the undersigned, at (202) 942-1870.
Please send all correspondence to us at the following ZIP code:
20549-0405.

Sincerely,



H. Roger Schwall
Assistant Director


cc: Michael McCoy

Custom Branded Networks, Inc.
November 22, 2004
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

DIVISION OF
CORPORATION FINANCE