April 27, 2006

Mail Stop 4561

Sheldon Silverman
Chief Executive Officer
WorldTradeShow.com, Inc.
9449 Balboa Avenue, Suite 114
San Diego, CA 92123

	Re:	WorldTradeShow.com, Inc.
      Amendment nos. 1, 2, 3 and 4 to  Form 10-SB
      Filed April 5, 6, and 11, 2006
      File no. 0-51126

Dear Mr. Silverman:

      We have reviewed your amendments and have the following
comments.

Business
Employees and Employee Agreements
1. Please see our prior comment 8.  Please update this section to
2006 and clarify the terms of the extensions of the consulting
agreements.

Item 2. Management`s Discussion and Analysis of Plan of Operation
Summary of Selected Financial Information
2. We note that you refer to January 31, 2005 as the nine-month
period in the caption even though your discussion refers to the
nine-
month period ended January 31, 2006.  Please revise.

Plan of Operation
3. See your response to prior comment 5.  Disclose that you have
no
written agreements for loans or financing from management.

Results of Operations
4. We further note that you present the results of operations for
the
period ended January 31, 2006 and its comparable period ended
January
31, 2005, while your caption describes the periods as January 31,
2005 and January 31, 2004, respectively.  Please revise.
5. Please explain what is meant by the sentence, "Overall the
Company
has minted its expenses to a minimum."

Executive Compensation
6. Your next amendment should include disclosure for the fiscal
year
ended April 30, 2006.  We note that your Option Grant Table is as
of
April 30, 2003.  With respect to Summary Compensation Table,
please
add a footnote explaining the components of the figures reflected
in
the "Other Annual Compensation" column.

Exhibits
7. Please see our prior comment 18.  Confirm, if true, that all
exhibits filed with this and any further amendments are in
executed
form.  You cannot file agreements in "to be executed" form as
exhibits.

Financial Statements
Notes to Financial Statements
Note 2 - Summary of Significant Accounting Polices
Revenue Recognition
Prior Comment Number 14
8. As previously requested in our prior comment number 27, tell us
who pays the Company commissions and the nature of the
arrangements
with the entity.  Further, explain the Company`s basis in GAAP for
recognizing revenue for commissions at the time customers present
records of room reservations.  In this regard, specifically
address
all of the revenue recognition requirements in SAB 104 and explain
how the presentation of room reservation records by the customer
meets all of those requirements.  Additionally, explain what you
mean
when you state that the customer presents records of room
reservations.  In this regard, to whom are customers presenting
room
reservation information.

Note 3 - Intangible, long-lived assets and goodwill
Dudesmart.com
Prior Comment Number 15
9. We note that you did not address our prior comment in your
response submitted on April 5, 2006.  As previously requested,
tell
us how you considered SFAS 142 in determining whether goodwill was
impaired as of April 30, 2005 or October 31, 2005.  Refer to
paragraphs 19 through 29 for guidance on testing goodwill for
impairment.  Tell us specifically how you considered that guidance
and provide us with your analysis in concluding whether goodwill
has
been impaired.  Further, clarify what you mean in the last
statement
of your disclosure that "[t]he Company from time to time evaluates
the fair value of its goodwill and at this time the company feels
fair market value of the goodwill."

Prior Comment Number 16
10. As requested in our prior comment, tell us how you considered
the
criteria in EITF 98-3 when concluding whether the Dudesman.com
transaction was an acquisition of a business or assets.
Specifically
discuss the guidance outlined in the EITF when discussing your
conclusions.  Your response should be specific and detailed in
nature
including references to the paragraphs considered within the EITF
when arriving at your conclusions.  Clarify what you mean when you
state that the "Company did not need to consider this transaction
with any kind of control relationship..."

Business.com.vn Marketing License Agreement
Prior Comment Number 17
11. We note your response to prior comment number 17 and it
appears
that the Company is providing marketing services to
Business.com.vn.
Considering the Company is providing services to Business.com.vn,
explain why you are paying a license fee.  In addition tell us how
royalties received, pursuant to the terms of this arrangement, are
determined.  Further tell us how you have considered the
provisions
of EITF 01-9 as it relates to the payment of a license fee by the
Company in return for receiving future royalties.

      You may contact Jason Niethamer at (202) 551-3855 or Thomas
Ferraro, at (202) 551-3225 if you have questions regarding
comments
on the financial statements and related matters.  Please contact
Hugh
Fuller, the examiner on your filing, at (202) 551-3853 or me at
(202)
551-3730 with any other questions.

Sincerely,


      Barbara Jacobs
      Assistant Director