-----BEGIN PRIVACY-ENHANCED MESSAGE-----
Proc-Type: 2001,MIC-CLEAR
Originator-Name: webmaster@www.sec.gov
Originator-Key-Asymmetric:
 MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen
 TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB
MIC-Info: RSA-MD5,RSA,
 EIYE+M2qIsZsPaUeemRtAiA8CU6oaw8jWvlmGPiwg8Tcu8xQKM0Isqb3HAt0q6oN
 3P3y53uHzgHvvczH9nSFYg==

<SEC-DOCUMENT>0001144204-05-010204.txt : 20061213
<SEC-HEADER>0001144204-05-010204.hdr.sgml : 20061213
<ACCEPTANCE-DATETIME>20050401163657
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0001144204-05-010204
CONFORMED SUBMISSION TYPE:	CORRESP
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20050401

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			AXIA GROUP, INC.
		CENTRAL INDEX KEY:			0000788738
		STANDARD INDUSTRIAL CLASSIFICATION:	SERVICES-MANAGEMENT CONSULTING SERVICES [8742]
		IRS NUMBER:				870509512
		STATE OF INCORPORATION:			NV
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		1324 N. MAGNOLIA AVE.
		CITY:			EL CAJON
		STATE:			CA
		ZIP:			92020
		BUSINESS PHONE:		6194441919

	MAIL ADDRESS:	
		STREET 1:		1324 N. MAGNOLIA AVE.
		CITY:			EL CAJON
		STATE:			CA
		ZIP:			92020

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	AXIA GROUP INC/UT
		DATE OF NAME CHANGE:	20010105

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	CYBERAMERICA CORP
		DATE OF NAME CHANGE:	19960620

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	CANTON INDUSTRIAL CORP
		DATE OF NAME CHANGE:	19950412
</SEC-HEADER>
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
                                                 [SPECTRUM LAW GROUP LETTERHEAD]

E-Mail:      mindeglia@spectrumlawgroup.com
File No.:    10040.02

                                 April 1, 2005

VIA EDGAR & U.S. MAIL

Ms. Cicely Luckey
Securities and Exchange Commission
450 5th Street, N.W.
Washington, D.C. 20459
Mail Stop 0304

      Re:   AXIA GROUP, INC.
            FORM 10-KSB FOR THE YEAR ENDED SEPTEMBER 30, 2004
            FORM 10-QSB FOR THE YEAR ENDED DECEMBER 31, 2004

Dear Ms. Luckey:

      On behalf of our client, Axia Group, Inc., a Nevada corporation  ("Axia"),
we are writing in response to the comments of the SEC staff  delivered by way of
its letter  dated March 15,  2005.  Set forth below are Axia's  responses to the
staff's  comments,  numbered in a manner to correspond to the order to which the
staff's comments were delivered.

YEAR ENDED SEPTEMBER 30, 2004

GENERAL

1.    In the beginning of January,  2005, Axia's board of directors,  Jody Regan
      and Dawnelle Patrick,  determined that it would be in the best interest of
      Axia to rescind Axia's acquisition of the capital stock of D&R Crane, Inc.
      Mr. Regan and Ms. Patrick were also the  controlling  stockholders  of D&R
      Crane  before  they  sold  D&R  Crane  to  Axia,  and as a  result  of the
      rescission,  they returned to their status as the sole stockholders of D&R
      Crane.  Axia's board of directors concluded that the cost of operating D&R
      Crane as a wholly-owned subsidiary of a publicly traded company outweighed
      the  benefits  associated  with D&R Crane's  status as a  subsidiary  of a
      publicly traded company. Further, Axia's board of directors concluded that
      Axia's  stockholders  would be  better  served  if it took on a  different
      management team more familiar with operating a publicly traded company and
      sought a different  business  opportunity  that would be better suited for
      the public  marketplace.  Accordingly,  on  January  11,  2005,  the board
      authorized the rescission of the D&R Crane acquisition.
<PAGE>

Ms. Cicely Luckey
Securities and Exchange Commission
April 1, 2005
Page 2

      The board of directors was not considering  the rescission  before the end
      of 2004,  and there were,  to current  management's  knowledge,  after due
      inquiry,  no  circumstances as of the date of the acquisition of D&R Crane
      that would have indicated that Axia's control of D&R Crane would have been
      temporary.

      Accordingly, Axia relied on APB 30 and EITF 95-18 for its determination to
      include D&R Crane's  financial  statements in the  consolidated  financial
      statements of Axia as it relates to the rescission,  since the measurement
      dated  under APB 30 would be  subsequent  to both  September  30, 2004 and
      December 31, 2004.  Axia also considered AU 560 paragraph 5 and determined
      that the  rescission  was an event that did not exist as of September  30,
      2004 but arose subsequent to that date, and therefore should not result in
      an  adjustment  to the  financial  statements.  Axia  provided  a footnote
      disclosure  of this event as set forth in AU 560 and stated that,  "[t]his
      rescission  resulted  in a  reduction  of assets  and  liabilities  on the
      Company's books in addition to the Company acquiring the shares of capital
      stock  that they had  initially  issued  for the  acquisition."  Since the
      rescission  resulted in a virtual elimination of assets and liabilities on
      the balance  sheet,  other than those  disclosed in the  subsequent  event
      note,  Axia determined that pro forma financial data would not provide any
      additional meaningful disclosure and was not required under AU 560.

QUARTER ENDED DECEMBER 31, 2004

GENERAL

2.    The following table sets forth the number of shares issued for services in
      the quarter ended December 31, 2004:

<TABLE>
<CAPTION>
Date of Issuance        Nature of Service Provided              Market Price      Common Shares         Value
- ----------------------------------------------------------------------------------------------------------------
<S>                <C>                                            <C>               <C>             <C>
10/22/2004         M&A Advisory Services                          $   0.08          1,000,000       $ 80,000.00

10/22/2004         M&A Advisory Services                          $   0.08          1,000,000       $ 80,000.00

10/22/2004         M&A Advisory Services                          $   0.08          2,000,000       $160,000.00

11/5/2004          M&A Advisory Services                          $   0.05          1,000,000       $ 50,000.00

11/10/2004         Sales & Marketing Consulting Services          $  0.006            600,000       $  3,600.00

11/10/2004         Sales & Marketing Consulting Services          $  0.006            600,000       $  3,600.00

11/12/2004         Sales & Marketing Consulting Services          $  0.004            600,000       $  2,400.00

11/12/2004         Sales & Marketing Consulting Services          $  0.004            600,000       $  2,400.00
</TABLE>

<PAGE>

Ms. Cicely Luckey
Securities and Exchange Commission
April 1, 2005
Page 3

<TABLE>
<CAPTION>
Date of Issuance        Nature of Service Provided              Market Price      Common Shares         Value
- ----------------------------------------------------------------------------------------------------------------
<S>                <C>                                            <C>               <C>             <C>
12/1/2004          M&A Advisory Services                          $0.00131          2,000,000       $  2,620.00

12/7/2004          M&A Advisory Services                          $0.00137          2,000,000       $  2,740.00

12/7/2004          M&A Advisory Services                          $0.00137          2,000,000       $  2,740.00

12/14/2004         M&A Advisory Services                          $0.00088          5,100,000       $  4,488.00

12/14/2004         Corp. Gov. Consulting Services                 $0.00088          5,100,000       $  4,488.00

12/14/2004         M&A Advisory Services                          $0.00088          5,100,000       $  4,488.00

12/15/2004         M&A Advisory Services                          $0.00081          8,150,000       $  6,601.50

12/15/2004         Corp. Gov. Consulting Services                 $0.00081          8,150,000       $  6,601.50

12/15/2004         M&A Advisory Services                          $0.00081          8,150,000       $  6,601.50
                                                                                  ------------------------------

                                                                                   53,150,000      $423,0368.50
                                                                                  ------------------------------
</TABLE>

In order to value the common stock shares issued for consulting services,  noted
above,  Axia used the historical  stock price for the market value of each share
on the date the board of directors  resolved to issue such  shares.  Please note
that these  calculations are made without reference to a 1-for-500 reverse stock
split which  occurred in January,  2005.  Please note that these  amounts do not
include  43,250,000  "pre-split"  shares issued to satisfy  accounts payable for
services rendered which were classified as "issuance of common shares for debt."

ITEM 3 - CONTROLS AND PROCEDURES

3.    Axia  does  not  believe  that  its  disclosure   regarding  controls  and
      procedures are neither confusing nor contradictory. The disclosure in Item
      3 states  that Axia's  management  has  concluded  that the  controls  and
      procedures  are  effective.  The  supplemental  disclosure  in the  second
      paragraph  essentially  state  that  management's   conclusions  regarding
      effectiveness  of the controls and  procedures  systems  could  ultimately
      prove to be wrong, either because no man-made system is perfect or because
      the system relies on certain assumptions regarding future events.

      While  Axia   believes   that  its   disclosures   are  not  confusing  or
      contradictory,  based on our discussions with the staff,  Axia would agree
      to change its disclosure in future filings from that quoted in the staff's
      letter of comments to the following:  "Because of these and other inherent
      limitations  of control  systems,  it is possible  that any design may not
      ultimately  succeed in  achieving  its stated  goals  under all  potential
      future conditions."
<PAGE>

Ms. Cicely Luckey
Securities and Exchange Commission
April 1, 2005
Page 4

      On behalf of Axia,  please be advised that the company has  endeavored  to
respond fully to each of the Staff's  comments.  We  acknowledge  and understand
that any comment from the staff  regarding these issues would not be binding and
would not  commit  the  staff in any  manner.  Further,  Axia  acknowledges  the
following:

      o     It is responsible for the adequacy and accuracy of the disclosure in
            its filings;

      o     Staff  comments  or  changes  to  disclosure  in  response  to staff
            comments do not foreclose the Commission from taking any action with
            respect to the filings; and

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

      Please advise us as soon as possible if the staff has any further comments
relating  to  either  of the  above-referenced  filings.  You  can  contact  the
undersigned  at (949)  851-4300.  Thank you in  advance  for your  courtesy  and
cooperation.

                                                         Very truly yours,

                                                         SPECTRUM LAW GROUP, LLP

                                                         /s/ Marc A. Indeglia
                                                         -----------------------
                                                         Marc A. Indeglia

MAI:wfr
cc:   Axia Group, Inc. (via facsimile)
      HJ & Associates, LLC (via facsimile)

</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>
-----END PRIVACY-ENHANCED MESSAGE-----
