Domark International, Inc.
                             1809 East Broadway #125
                              Oviedo, Florida 32765

November 17, 2008

VIA EDGAR

Securities and Exchange Commission
100 F Street, N.W.
Division of Corporate Finance
Washington, D.C. 20549

     Re: Item 4.01 Form 8-K
         Filed September 11, 2008
         File No. 333-136247

Dear Mr. Kempf and Mr. Littlepage:

Below are the responses to your comments on to your letter of October 9, 2008:

Form 8-K
Item 4.01

1.   The disclosure in the third and fourth paragraphs of Item 4.01 of your Form
     8-K should be clarified. It should state whether during the registrants two
     most recent fiscal years and any subsequent interim period through the date
     of resignation,  declination or dismissal there were any disagreements with
     the former accountant on any matter of accounting  principles or practices,
     financial  statement  disclosure,  or auditing  scope or  procedure,  which
     disagreement(s),  if  not  resolved  to  the  satisfaction  of  the  former
     accountant, would have caused it to make reference to the subject matter of
     the  disagreement(s)  in  connection  with  its  reports.  In the  event of
     disagreement(s)   and/or   reportable   event(S),   provide  the   specific
     disclosures required by Item 304(a)(1)(iv) and (v) of Regulation S-K.

     We have noted your comment and revised the disclosure.

2.   Similarly,  please  clarify the fifth  paragraph  of Item 4.01 of your Form
     8-K.  Indicate  whether there were  consultations  with your new accountant
     during the two most recent fiscal years and the subsequent interim periods,
     prior to September 8, 2008, the date your new  accountant was engaged.  See
     Item 304(a)(2)(iv) of Regulation S-K.

     We have noted your comment and revised the disclosure.

Exhibit 16.1

3.   Tell us why the letter from your former accountant,  filed as an exhibit to
     this Form 8-K, was provided and signed by Chang Parker,  CPA PhD. while the
     audit report  included in your May 31, 2007 Form 10-KSB was provided by and
     signed  by  Chang  G.  Park,  CPA.  As  appropriate,  provide  us  evidence
     supporting Mr. Parker's qualification to practice before the Commission as

     he  does  not  appear  to  be  registered  with  the  California  Board  of
     Accountancy or with the Public Company Accounting Oversight Board.

     We have noted your comment and revised the disclosure. In addition, we have
     confirmed that our prior auditor,  Chang Park,  CPA, is registered with the
     California  Board of  Accountancy  and with the Public  Company  Accounting
     Oversight Board.

The Company hereby acknowledges:

*    The Company is responsible  for the adequacy and accuracy of the disclosure
     in the filings;

*    Staff  comments or changes to disclosure  in response to staff  comments in
     the filings  reviewed by the staff 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.

Sincerely,


/s/ R. Thomas Kidd
--------------------------------
R. Thomas Kidd
Chief Executive Officer
Date: November 17, 2008