UPLOAD: SEC-generated letter

January 26, 2005


Mail Stop 0409

Edward F. Panos
President
Common Horizons, Inc.
620 Tam O`Shanter
Las Vegas, NV 89109

Re: Common Horizons, Inc.
Amendment No. 2 to Form SB-2, filed on January 14, 2005
File No. 333-119366

Dear Mr. Panos:
We have reviewed your filing and have the following
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
supplemental information so we may better understand your
disclosure.
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 SB-2
Significant Employees, page 22

1. We note your response to prior comment 4. Please file the Chef
Live agreement as an exhibit to your next amendment.

Security Ownership of Certain Beneficial Owners and Management,
page
22

2. We note your response to prior comment 5. Similarly, please
supplementally tell us whether Mr. Oram`s ownership includes those
shares held by Carolyn, Douglas and Paul Oram.

Liquidity and Capital Resources, page 38

3. We note your response to prior comment 7 and your statements
that
you plan to list your stock or have your stock be approved for
listing. Please revise the second paragraph to clarify that you
plan
to have your common stock "quoted" on the over-the-counter
bulletin
board and that a market for your common stock may never develop.

Financial Statements

4. With respect to our previous comment 9, we reiterate our
request
that you include audited financial statements as of and for a
period
ending within 135 days of the filing as you have existed for a
period
of less than one year. Refer to Item 310(a) of Regulation S-B.

Other

As appropriate, please amend your registration statement in
response to these comments. 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 supplemental 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.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings 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.

We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement. Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration. Please provide this
request at least two business days in advance of the requested
effective date.

You may contact Jay Spinella, Staff Accountant, at (202) 942-7323
or
Steven Jacobs, Senior Staff Accountant, at (202) 824-5222 if you
have
questions regarding comments on the financial statements and
related
matters. Please contact Amanda McManus, Staff Attorney, at (202)
942-7184 or the undersigned at (202) 942-2987 with any other
questions.


Sincerely,


Peggy Kim
Senior Counsel



cc: Chad Wiener, Esq. (via facsimile)
Cane & Associates, LLP
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Common Horizons, Inc.
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