March 7, 2005



Mail Stop 3-8

By Facsimile and U.S. Mail

Todd M. Axelrod
President
Gallery of History, Inc.
3601 West Sahara Avenue
Las Vegas, Nevada, 89102

Re:	Form 10-KSB for the year ended September 30, 2004
	Filed December 29, 2004
	File No.  0-13757

Dear Mr. Axelrod:

      We have reviewed your filing and have the following
comments.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
Please be as detailed as necessary in your explanation.   After
reviewing this information, we may or may not raise additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

FORM 10-KSB FOR THE YEAR ENDED SEPTEMBER 30, 2004

Item 7 - Financial Statements

Accountants Report

1. The report of your accountants, Piercy, Bowler, Taylor & Kern,
does not make reference to the standards of the Public Company
Accounting Oversight Board (United States). Please amend your
filing
to revise the audit report.



Statement of Cash Flows

2. We note that your statement of cash flows does not provide a
reconciliation of net income to net cash flows from operating
activities as required by paragraph 29 of SFAS 95. Please amend
your
filing to provide this reconciliation.

Notes to the Financial Statements

3. Revise your notes to disclose the fair value of your financial
instruments in accordance with paragraphs 10-15 of SFAS 107. If
the
fair value of your financial instruments approximates the book
value,
please provide a statement to that effect.

Item 8a - Controls and Procedures

4. We note your disclosures that you evaluated your disclosure
controls within 90 days prior to the date of the report. Amend
your
filing to state that you evaluated your disclosure controls and
procedures as of the end of the period covered by the report. See
Regulation S-K Item 307.

5. We note your statement that your chief executive officer and
you
chief financial officer "have concluded that....disclosure
controls
and procedures are adequate." It does not appear that your
certifying
officers have reached a conclusion that your disclosure controls
and
procedures are effective. Please amend your filing to disclose
that
your disclosure controls and procedures are effective, if true.

 	Please respond to these comments within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
letter
with your responses to our comments and provide any requested
supplemental information.  Please understand that we may have
additional comments after reviewing your responses to our
comments.
Please file your response letter on EDGAR as a correspondence
file.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

      In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments 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.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	If you have any questions regarding these comments, please
direct them to John Cannarella, Staff Accountant, at (202) 824-
5384
or, in his absence, to the undersigned at (202) 942-2823.  Any
other
questions regarding disclosure issues may be directed to H.
Christopher Owings, Assistant Director, at (202) 942-1900.


Sincerely,



Michael Moran
Branch Chief



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Gallery of History, Inc.
March 7, 2005
Page 1