CORRESP 5 filename5.txt KINGSTON MINES LTD. 106-1990 S.E. KENT AVE. VANCOUVER BRITISH COLUMBIA V5P 4X5 TEL: (604) 642-9561 FAX: (604) 648-8902 August 10, 2006 VIA EDGAR AND COURIER Pamela A. Long Assistant Director Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, N.W. Washington, D.C. 20549 Re: KINGSTON MINES LTD. FORM SB-2 FILED APRIL 12, 2006 COMMISSION FILE NO. 333-133232 Dear Ms. Long: In connection with the above-captioned filing, we are filing with the Commission, via Edgar, the following documents relating to the registration of Common Stock: A. Pre-Effective Amendment No. 3 to our Registration Statement on Form SB-2 (the "Registration Statement"); and B. Four copies of the Registration Statement, marked to indicate the changes made by Pre-Effective Amendment No. 3. The Registration Statement has been amended to respond to the Staff's letter of non-accounting and accounting comments dated July 27, 2006. Our responses to the Staff's comments are set forth below in the following paragraphs numbered to correspond to the comments in the Staff's letter. Any capitalized terms used in this letter shall have the meanings ascribed to them in the Registration Statement. FORM SB-2 General 1. In response to the Staff's comment, we updated our financial statements. Available Information, page 32 2. In response to the Staff's comment we have deleted the statement (page 32). Should the Staff need additional information or have questions concerning our response, please do not hesitate to contact us. Yours very truly, /s/ Lou Hilford Lou Hilford President & CEO Enclosures