SMI PRODUCTS, INC.
                                3503 Cedar Locust
                               Sugarland, TX 77479







May 16, 2006

MAIL STOP 3561

Tia Jenkins
Senior Assistant Chief Accountant
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549


RE:   SMI Products, Inc. ("Registrant")
      Form 10-KSB/A
      Filed April 4, 2006
      File Number 333-55166

Ladies/Gentlemen:

In response to your comments  dated April 18, 2006,  the Registrant has made the
following amendments, corresponding to your enumerated paragraphs:

ITEM 8A. CONTROLS AND PROCEDURES

1.   The document has been amended to include the information  required by Items
     307 and 308(c) of Regulation S-B.

ITEM 14. PRINCIPAL ACCOUNTANT FEES AND SERVICES

2.   The document has been amended to include the  information  required by Item
     9(e) of Schedule 14A.

In addition, the Registrant hereby acknowledges that:

     1.   the  Registrant  is  responsible  for the adequacy and accuracy of the
          disclosure in the filing;

     2.   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

     3.   the  Registrant  may not asset  staff  comments  as a  defense  in any
          proceeding initiated by the Commission or any person under the federal
          securities laws of the United States.

If you have any further questions or comments  regarding this filing,  please do
not hesitate to contact me.


Very truly yours,


/s/ JAMES M. CHARUK
__________________________
    James M. Charuk
    President and Director


cc: Amisano Hanson, Chartered Accountants
    Michael J. Morrison, Esq.