October 18, 2005



Mr. Edward D. Ford
Acting Chief Accounting Officer
International Gemini Technology Inc.
#208 - 828 Harbourside Drive
North Vancouver, British Columbia, Canada V7P 3R9


	Re:	International Gemini Technology Inc.
		Form 20-F for Fiscal Year Ended December 31, 2004
Filed June 30, 2005
Response Letter Dated September 22, 2005
Form 20-F/A for Fiscal Year Ended December 31, 2004
Filed September 22, 2005
		File No. 0-14740


Dear Mr. Ford:

      We have reviewed your filings and response letter and have
the
following comments.  We have limited our review of your filing to
those issues we have addressed in our comments. Where indicated,
we
think you should revise your document in response to these
comments.
If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unnecessary.  Please be
as
detailed as necessary in your explanation.  In some of our
comments,
we may ask you to provide us with information so we may better
understand your disclosure.  After reviewing this information, we
may
raise additional comments.

Form 20-F/A for the Fiscal Year Ended December 31, 2004

Operating and Financial Review and Prospects, page 8

1. Please expand your revised disclosure within MD&A, provided in
response to prior comment one, to explain how the income you earn
from providing consulting services can "fluctuate on the basis of
postal rate increases, or reductions in courier or long distance
phone rates."


Controls and Procedures, page 19

2. Please reconcile your previous disclosure that "Specific
controls
and procedures were not implemented by the end of fiscal year
2004"
with the revision you have made to your amended Form 20-F that
"the
CEO and CAO have concluded that the Company`s disclosure controls
and
procedures are effective to ensure that information required to be
disclosed by the Company in reports that it files or submits under
the Securities Exchange Act of 1934 is recorded, processed,
summarized and reported within the time periods specified in
Securities and Exchange Commission rules and forms."  Please note
that Item 15(a) in Form 20-F states that "Where the Form is being
used as an annual report filed under Section 13(a) or 15(d) of the
Exchange Act, disclose the conclusions of the issuer`s principal
executive and principal financial officers, or persons performing
similar functions, regarding the effectiveness of the issuer`s
disclosure controls and procedures (as defined in 17 CFR 240.13a-
15(e) or 240.15d-15(e)) as of the end of the period covered by the
report, based on the evaluation of these controls and procedures
required by paragraph (b) of 17 CFR 240.13a-15 or 240.15d-15."

3. You also state that there were no "significant changes" in your
"internal controls" and no factors that could "significantly
affect"
these controls subsequent to the date of their evaluation.
However,
Item 15 of Form 20-F requires that you disclose any change in the
issuer`s "internal control over financial reporting" identified in
connection with the evaluation required by paragraph (d) of
Exchange
Act Rules 13a-15 or 15d-15 that occurred during the period covered
by
the annual report that has "materially affected, or is reasonably
likely to materially affect, the issuer`s internal control over
financial reporting."  See also paragraph 4(d) of the
Certifications
shown in paragraph 12 of the Instruction to Item 19.  Revise your
disclosure accordingly.

Note 7. Changes in Non-Cash Working Capital Balances Relating to
Operations, page 8

4. We have reviewed the reconciliation provided in response to
prior
comment five and are unable to determine why you would reclassify
the
investment sale receivable.  Upon further review of you Statements
of
Cash Flows for the 2004 period presented, we note that the total
presented for "Net cash from (used in) operating activities" does
not
compute mathematically.  Please review your presentation and
revise
as appropriate.

Closing Comments

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

      You may contact Jennifer Goeken at (202) 551-3721 if you
have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3683 with any other
questions.



								Sincerely,



								Jill S. Davis
								Branch Chief

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Mr. Edward D. Ford
International Gemini Technology Inc.
October 18, 2005
Page 1




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