January 10, 2006

Mail Stop 4561

Kevin M. Stunder
President
Madison Explorations, Inc.
525 Seymour Street, Suite 807
Vancouver, BC, CANADA V6B 3H7


	Re:	Madison Explorations, Inc.
		Amendment No. 2 to Form 10-SB filed December 22, 2005
		Amendments to Form 10-QSB for June 30, 2005 and
                           September 30, 2005 filed December 23,
2005
      File no. 0-51302


Dear Mr. Stunder:

      We have reviewed your amended Form 10-SB and amended Forms
10-
QSB and have the following comments.

Part I
Item 1. Description of Business
1. As requested in comment 2 of our November 29, 2005 letter,
please
disclose how Madison became familiar with Echo Resources, Inc.  In
this regard, we note that there is a Mr. William A, Montgomery who
was the principal shareholder of Echo in an earlier incarnation as
Alphacon Corporation and may still be an officer of Echo.  Please
advise if Mr. William Montgomery is related to Dr. Joseph
Montgomery,
Vice President and Director of Madison Explorations, Inc., and, if
so, disclose that relationship here and under "Item 7. Certain
Relationships and Related Transactions."
2. Please also advise supplementally whether or not consideration
is
being given to merging Echo and Madison.
3. We note that you have filed a consent of your accounting firm
that
consents to the use of their name in "the Prospectus."  Since
there
is no prospectus involved in a Form 10-SB registration statement
and
that no consent is required by Form 10-SB, please advise us why
this
language has been included.

Amended Forms 10-QSB for June 30, 2005 and September 30, 2005
Item 4. Evaluation of Disclosure on Controls and Procedures
4. We note your revised disclosure in response to prior comment
20.
Please ensure that future filings contain the entire definition of
the term "controls and procedures" in Exchange Act Rule 13a-15(e)
or
that you refer to the rule itself.
5. Please revise the "Conclusions" paragraph to state clearly
that:
* the controls and procedures are designed to provide reasonable
assurance that the necessary information as defined in Rule 13a-
15(e)
is available to the Chief Executive Officer and to the Chief
Accounting Officer on a timely basis and
* the two specified officers state, if true, that the controls and
procedures are effective in this function.
Closing

      You may contact Babette Cooper at (202) 551-3396 or Terence
O`Brien, the Accounting Branch Chief at (202) 551-3355 if you have
questions regarding comments
regarding the financial statements and related matters.  Please
contact me at (202) 551-3730 with any other questions.

								Sincerely,



								Barbara C. Jacobs
								Assistant Director