LANDBANK GROUP, INC.
                             7030 Hayvenhurst Avenue
                             Van Nuys, CA 91406-3801
                                 (818) 464-1640

                                                               December 28, 2006

Karen J. Garnett
Assistant Director
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

Dear Ms. Garnett:

Pursuant to your letter dated December 15, 2006, I herewith submit the following
responses to the SEC's comments, which were set forth therein:



General:


1.       Please  note that the Form 10 goes  effective  by lapse of time 60 days
after the original filing date,  pursuant to Section  12(g)(1) of the Securities
Exchange Act of 1934.  Upon the expiration of this 60-day time period,  you will
be subject to the reporting  requirements  under Section 13(a) of the Securities
Exchange Act of 1934. In addition,  we will continue to review your filing until
all of our comments have been addressed.

No response necessary



Business of Issuer, page 4
- --------------------------


2.       Please  revise to  describe  the tax lien  foreclosure  process in more
detail.  Discuss the rights,  if any, of property  owners to reclaim  properties
after they have been  purchased  in the  foreclosure  proceedings.  Describe any
encumbrances that may remain with the property following the foreclosure process
and clarify when these  properties will have a clear title. In addition,  please
revise the risk factors section as appropriate to describe any risks  associated
with purchasing properties through tax lien foreclosure.

The Company has complied with this comment by adding the requested disclosure to
Item 1 under the sections entitled "Business of Issuer", commencing on page 4 of
the registration statement (redlined version to be provided) and "Risk Factors",
commencing on page 6 of said statement.



Reports to Security Holders, page 5
- -----------------------------------


3.       Please update the SEC address. 100 F Street, NE, Washington, DC 20549.

The address has been amended accordingly.



Risk Factors, page 6
- --------------------


4.       Please  review  all  risk  factor  headings  to  ensure  that a risk is
identified,  rather the merely a fact about your business.  For example, we note
the following risk factor headings:

     o    We depend on key personnel and affiliates
     o    Classification of the Company's securities as a "Penny Stock"

The Company has complied  with this comment by revising  the  disclosure  in the
Item 1 "Risk Factors" section.



Our principal stockholders have broad control over our operations, page 7
- -------------------------------------------------------------------------

5.       Please expand the disclosure to address  significant  corporate actions
that can be undertake unilaterally by your principal stockholders.


The Company has complied  with this comment by revising the relevant  disclosure
in the  Item  1  "Risk  Factors"  section,  on  page  8 in  the  redline  of the
registration statement.



Management's Discussion and Analysis or Plan of Operations, page 10
- -------------------------------------------------------------------

6.       Tell us what  consideration  you have given to disclosing your critical
accounting policies. Refer to the guidance in FR- 72.

Based on the  guidance  set forth in FR-60 and FR-72,  the Company  reviewed its
accounting  policies  (as  summarized  in note 1 to our  financial  statements),
including consideration as to whether the nature of any estimates or assumptions
underlying  our  accounting   measurements   is  material  due  to  a  level  of
subjectivity or judgment  necessary to account for highly  uncertain  matters or
the  susceptibility  of such matters to change,  and whether such  estimates and
assumptions  had a  material  impact on the  Company's  financial  condition  or
operating performance.  Based on this review and consideration,  we respectfully
determined  that there were no underlying  material  underlying  assumptions  or
estimates or implications of uncertainties  associated  therewith  necessitating
disclosure under FR-72. For instance,  the Company has no fixed assets, does not
maintain any short-term highly liquid debt instruments,  and recognizes revenues
in accordance  with FASB 66, only upon receipt of full payment and expiration of
any  rescission  period.  Accordingly,  we do  not  rely  on  any  estimates  or



assumptions in recording these items. Inventory is reviewed on a quarterly basis
in an attempt to identify properties that may have become impaired (difficult or
impossible  to  sell),  and,  depending  on the  results  of  that  review,  the
appropriate  impairment charge is recorded.  While there are certain assumptions
made as to the fair market value of these properties for purposes of determining
the impairment charge, these assumptions are based on objective market data, and
in our view are not material.  Further,  since operations only began in 2005 and
due in large  measure to our  developed  acquisition  strategy,  only a very few
properties  have  become  impaired,  and  thus  we do  not  believe  that  these
assumptions  have a material  impact on the  Company's  financial  condition  or
operating performance.


7.       Please expand the  "Overview" to discuss how you finance your business.
The Company has complied  with this comment by revising the relevant  disclosure
in the Item 2 "Management's  Discussion and Analysis" section, on page 12 of the
redlined version of the registration statement.



Operating Expenses, page 11
- ---------------------------

8.       Please provide independent  third-party support for your statement that
there was a marked increase in customer demand for properties" in 2006.

In making this statement,  we were attempting to explain why the Company decided
to hire new acquisition  specialists in February 2006. As stated,  the Company's
decision was based on its determination  that there was a marked increase in the
demand for our  properties.  As we do not have specific  third party support for
this  determination,  and as it is anecdotal in nature, the Company has complied
with this comment by deleting this statement in Item 2 "Management's  Discussion
and Analysis."



Description of Property, page 15
- --------------------------------


9.       Please  describe  the amount paid in 2005 for the pro rata lease on the
Phoenix office.

On May 17, 2005, the Company entered into a sublease agreement with Mentoring of
America,  LLC ("MOA"), an affiliate,  to lease office space at MOA's facility in
Phoenix,  Arizona.  Per the  terms of the  agreement,  the  Company  is to pay a
prorated  share of MOA's  monthly rent expense,  which equates to  approximately
13.33%. This percentage is based on the total square footage used by the Company
(1,000 sq. ft.) divided by the total square footage of MOA's facility (7,500 sq.
ft.).  The term of this lease is  thirty-two  (32) months,  beginning on June 1,
2005 and  terminating  on January  31,  2008,  and MOA, at its  discretion,  can
instruct  the Company not to remit cash payment for the monthly rent and instead
apply the monthly rent fee to any outstanding  inter-company balance between the
companies.  During  fiscal year 2005,  the Company  recorded  monthly  rent fees
totaling  $12,570,  which included June 2005 through December 2005. Rent expense
totaled $16,663 for the nine months ended  September 30, 2006. The  registration
statement has been amended accordingly.



10.      Please update your interim inventory figures to September 30, 2006.

The Company has complied  with this  comment by updating  the relevant  table to
September  30,  2006  in  Item 3  "Description  of  Property"  on page 18 of the
redlined registration statement.


11.      Please  expand  your  inventory  disclosures  to  show a  breakdown  by
geographic region.

The  Company  has  complied   with  this  comment  by  expanding  our  inventory
disclosures  in the Item 3  "Description  of  Property"  section to include  the
requested breakdown. See page 18 in the redline of the registration statement.


12.      Please  expand  your  inventory   disclosures  to  show  the  value  of
properties  that are being  marketed and the value of properties  that are being
prepared for marketing.

The Company has complied with this comment by expanding our inventory
disclosures in the Item 3 "Description of Property" section to include the
requested value information. See page 18 in the redline of the registration
statement.



Directors. Executive Officers. Promoters and Control Persons, page 17
- ---------------------------------------------------------------------


13.      Please disclose five years of business experience for Mr. Hewitt.

The registration statement has been amended to that effect.



Certain Relationships and Related Party Transactions, page 20
- -------------------------------------------------------------

14.      Please include  detailed  disclosures  regarding your affiliate  loans,
including interest, maturity and repayment terms, the identities of the lenders,
the dates the loans were made and the purposes of the loans.

The Company has complied with this comment by adding the required  disclosure in
the Item 7 "Certain Relationships and Related Transactions" section. See page 23
in the redline of the registration statement.


15.      Please include more thorough disclosure  regarding the transfer of ISNG
to QED Storage. We note that in some instances it is described as a spin-off and
in others as a transfer to QED.

The Company has complied  with this comment by revising the relevant  disclosure
in Item 7 "Certain Relationships and Related Transactions" and making conforming
changes elsewhere in the registration statement where necessary.  See page 23 in
the redline of the registration statement.



Description of Securities, page 21
- ----------------------------------


16.      Please  revise the first  bullet to c1arify how you are  ""eliminating"
cumulative voting.

With respect to this comment,  the Company would respectfully like to clarify as
follows:  the language as written was intended to describe the provisions of the
charter and Delaware General  Corporate Law ("DGCL") that have a limiting effect
on change of control.  Section 214 of DGCL provides that cumulative  voting only
exists if provided for in the Certificate of  Incorporation.  Our Certificate of
Incorporation  does  not  provide  for  cumulative  voting,  thereby  in  effect
eliminating  cumulative  voting.  The Company has  therefore  complied with this
comment by deleting this bullet point to avoid any confusion. See page 24 in the
redline of the registration statement.



Recent Sales of Unregistered Securities, page 24
- ------------------------------------------------


17.      Please  revise  subparagraph  (e) to identify  the  "advisors"  and the
services they performed.

The Company has complied  with this comment by revising the relevant  disclosure
in Part II,  Item 4 "Recent  Sales of  Unregistered  Securities"  to include the
requested information. See page 27 in the redline of the registration statement.



Financial Statements
- --------------------

Landbank Group, Inc. and Subsidiary
- -----------------------------------



18.      Please  update  your  financial  statements  pursuant to Item 31 (g) of
Regulation S-B.

The unaudited  consolidated  financial  statements for the three- and nine-month
periods ended September 30, 2006 are included in Part F/S, and the corresponding
discussion in Item 2, Management's Discussion and Analysis has also been updated
accordingly.


19.      It  appears  that  iStorage  Networks  was an  operating  company as of
December 31, 2005. Accordingly, explain to us how you determined that there were
no assets or  liabilities  that were  required to be recorded at fair value as a
result of the merger  with  LandBank  LLC.  Additional1y,  explain to us how you
determined  that LandBank LLC was the  accounting  acquirer in  accordance  with
paragraph 17 of SFAS 141. Tell us what consideration you have given to including
this information in your financial statement disclosures.

With respect to this comment,  the Company  respectfully  provides the following
explanation.  On January 26,  2006,  the Company  acquired all of the assets and
liabilities  of Landbank,  LLC,  whereupon  the owners of Landbank,  LLC assumed



control of the  Company.  Immediately  prior to the merger,  and pursuant to the
terms of the purchase agreement with Landbank,  LLC, the Company divested all of
its previous  operations,  assets,  and liabilities,  resulting in the Company's
balance  sheet  showing no assets and no  liabilities  at the time of its merger
with Landbank, LLC. Therefore,  post-merger,  the only assets, liabilities,  and
business operations reflected in the Company's financial statements are those of
Landbank,  LLC,  which is now a  wholly  owned  subsidiary  of the  Company.  In
accordance  with paragraph 17 of SFAS 141, "all else being equal,  the acquiring
entity is the combining  entity whose owners as a group retained or received the
larger  portion of the voting rights in the combined  entity."  LandBank LLC was
determined  to be the  accounting  acquirer  since the  owners of  LandBank  LLC
received the larger  portion of the voting rights (90%) in the combined  entity.
This fact has been  considered by the Company and its auditors in disclosing the
reverse acquisition in note 1 to the consolidated financial statements.



Consolidated Balance Sheet, page F-4.
- -------------------------------------


20.      Please  advise us of your basis for the  classification  of inventory -
land  parcels  as a current  asset:  or  revise  your  classification  as deemed
appropriate.

With respect to this comment,  the Company  respectfully  provides the following
supplemental  information.  The Company is in the business of buying land at tax
foreclosure auctions, and other liquidation venues, and reselling that land at a
profit.  The Company does not make  improvements to the land, or does it buy the
land as part of a long-term  investment  strategy.  The Company's goal is to buy
properties  at low cost and to resell  them as quickly as  possible,  preferably
within 90 days of the date of purchase.  Based on this business  model,  and the
Company's history of turning over properties quickly, inventory is recorded as a
current asset.


21.      Please advise us and revise to disclose whether the accounting acquirer
and the accounting  acquiree have the same fiscal  year-end.  To the extent that
the year- ends of the companies differed,  tell us which year-end was adopted by
the combined company.

Both the  acquirer  and  acquiree  had the same fiscal  year-ends.  The combined
company has retained the same fiscal year-end.  The  registration  statement has
been revised accordingly.



Inventory, page F-8.
- --------------------


22.      Please  explain to us the method used to account for the impairment and
disposal  of  long-lived  assets,  such as when you  measure  and  recognize  an
impairment  loss. Tell us what  consideration  you have given to disclosing this
information in your financial statements.

With respect to this comment,  the Company  respectfully  provides the following
explanation. The Company's inventory consists of land parcels that are purchased
for resale  purposes,  and,  except for special  circumstances,  do not normally
remain in inventory for a prolonged  period of time. Since these parcels are for



resale  purposes only,  they are classified as inventory,  instead of long-lived
assets.  The Company  evaluates  its inventory at the lower of cost or market at
the  balance  sheet date and for any  permanent  impairment  in the value of the
assets.  The Company has not yet experienced  any impairment,  as the Company so
far has been  successful  in its  ability to resell the  properties  that it has
purchased.  As the Company to date has not experienced  any asset  impairment or
disposal of  long-lived  assets,  we did not view this as a material  accounting
policy at this time.



Financial Statements
- --------------------

Landbank, LLC
- -------------


23.      We note that  Landbank,  LLC was organized in December 2004 and did not
have any  operations  in 2004.  Please  advise us and revise your  disclosure to
state, if true,  that no (or nominal) assets or liabilities  existed as December
31, 2004.

We confirm that  Landbank,  LLC had no assets or  liabilities as of December 31,
2004. The registration statement is amended accordingly.


24.      Please  amend  to  present  the  2005  and  2004  historical  financial
statements  of  the   Registrant   after  giving   retroactive   effect  to  the
recapitalization.  Please note that both the equity section of the balance sheet
and the earnings per share of Landbank.  LLC should be retroactively restated to
reflect the effect of the  exchange  ratio  established  in the reverse  merger.
Please have your  independent  registered  public  accounting  firm update their
report as appropriate.

The Company  respectfully  believes that its 2005 and 2004 historical  financial
statements  should not be  retroactively  restated  to reflect the effect of its
merger with Landbank, LLC, for the following reasons:

(i) With respect to 2004, Landbank, LLC did not commence operations,  and had no
assets or liabilities,  until 2005. Thus, there would have been no net effect of
the  recapitalization  on the Company's  results for 2004. In fact, as the Staff
draws  attention  in  Comment  25, as  Landbank,  LLC was  determined  to be the
accounting acquirer, the inclusion of the 2004 financial statements for iStorage
is upon further  reflection  inconsistent with this determination and the result
of  over-disclosure  on our part, and should we believe be omitted completely in
order to avoid misleading investors.

(ii)With  respect to 2005,  the Company  divested  all of its  previous  assets,
liabilities,  and business operations immediately prior to the merger in January
2006. We respectfully draw the Staff's attention to note 9 in the 2005 financial
statements for iStorage which states that "had the transaction  been consummated
by  December  31,  2005,  substantially  all of the  balance  sheet  and  income
statement  amounts  reflected  in this report  would have been  removed with the
subsidiary." There was therefore a complete separation of activities between the
end of 2005 and the beginning of 2006, with the Company's operations during 2005



being completely  unrelated to those of its ongoing  operations  post-2005.  The
Company's goal,  throughout the merger, was to structure the transaction so that
the  assets,  liabilities,  and  operating  results  of  the  previous  business
operations were flushed out,  resulting in a corporate,  and legal,  entity that
would clearly,  and accurately,  reflect the operating results of only Landbank,
LLC, which, post-merger, is the lone operating entity. Thus, we believe that any
restatement of the 2005 financial statements to include the operating results of
the Company's previous  operations would be both irrelevant and misleading,  and
therefore in the best interest of investors to omit such restatement.



Financial Statements
- --------------------

iStorage Networks, Inc. and Subsidiary
- --------------------------------------


25.      Please   clarify  for  us  your  reason  for  including  the  financial
statements of iStorage Networks, Inc.

The iStorage  Networks,  Inc.  financials were presented in an effort to provide
full  disclosure in that iStorage  Networks,  Inc. was the legal  acquirer,  but
their presence adds nothing save confusion to an  understanding  of the combined
entity. These financials are not included in the amended registration statement,
Part F/S.


I hope the above has adequately addressed each and every comment.


                                                     Sincerely,

                                                     /s/ Doug Gravink

                                                     Doug Gravink
                                                     Chief Executive Officer