LETTER 1 filename1.txt Mail Stop 3561 September 9, 2005 Matthew J. Hoogendoorn Chief Financial Officer Clearly Canadian Beverage Corporation 2489 Bellevue Avenue West Vancouver, British Columbia, Cananda V7V 1E1 RE: Clearly Canadian Beverage Corporation Form 20-F for Fiscal Year Ended December 31, 2004 Filed June 30, 2005 File No. 000-15276 Dear Mr. Hoogendoorn: It appears your Form 20-F excludes Item 18 financial statements. Please amend your filing immediately to include all disclosures required by Form 20-F. We may have further comments after reviewing your amended filing. If you have any questions please direct them to Adam Phippen, Staff Accountant, at (202) 551-3336. In his absence, your questions may be directed to me at (202) 551-3843. Sincerely, George F. Ohsiek, Jr. Branch Chief ?? ?? ?? ??