December 2, 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.
Response Letter Dated November 1, 2005
		File No. 0-14740


Dear Mr. Ford:

      We have reviewed your 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-2 for the Fiscal Year Ended December 31, 2004

Controls and Procedures, page 19

1. We continue to evaluate your response to prior comment two.  In
the meantime, please support your disclosure, added in response to
prior comment three, that "No changes in our disclosure controls
and
procedures or other facts have occurred during the fiscal year
covered by this annual report on Form 20-F that would materially
affect or be reasonably likely to materially affect our disclosure
controls and procedures" in light of your response where you
indicate
that "During the year ended December 31, 2004 the Company did
implement controls and procedures."

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.
December 2, 2005
Page 1




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