July 31, 2006

Susann Reilly, Esq.

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E., Mail Stop 3561

Washington, DC 20549

Re:	Signet International Holdings, Inc.
	Form SB-2 filed June 2, 2006
	File No. 333-134665

Dear Ms. Reilly:

We represent Signet International Holdings, Inc. (the “Company”). We are in receipt of your letters dated July 10, 2006 and July 11, 2006 and the following sets forth the Company’s responses thereto:

Comment Letter Dated July 10, 2006

General

We note that the registration statement registers the resale of 2,449,000 shares of common stock, or approximately 63% of the 3,852,000 shares of common stock outstanding. It appears that this resale transaction of this amount may be, in essence, an offering by or on behalf of the issuer for purposes of Rule 415(a)(4) of Regulation C under the Securities Act. For these sales to occur “at the market,” the provisions of Rule 415(a)(4) must be satisfied. As your offering does not appear to meet these provisions, an “at the market” offering would not appear permissible. Therefore it would appear that the shares being offered must be sold at a fixed price for the duration of the offering. Please revise or provide a detailed analysis, if you feel this position does not apply to you.

ANSWER:

The Company has reduced the number of shares it is registering to 1,224,500 shares which represents approximately 32% of the 3,852,000 total outstanding shares of the Company.

Registration Statement Cover Page

2.	Please include the name, address and telephone number of the agent for service.

ANSWER:

The cover page of the registration statement has been amended to disclose that the name, address and telephone number of the agent for service is Ernie Letiziano, Chief Executive Officer, 205 Worth Avenue, Suite 316 Palm Beach, Florida 33480, (561) 832-2000.

Cover Page of the Prospectus

3.	Highlight the cross-reference to the risk factors by prominent type or in another manner.

ANSWER:

The cover page of the prospectus has been amended to highlight the cross-reference to the risk factors by capitalizing and emboldening such language.

4.	Clarify on the cover page, the summary and in the business section, that you do not have international operations.

ANSWER:

The cover page of the prospectus, summary, and business sections have been revised to disclose that the business does not have international operations.

Table of Contents

5.	Please include page numbers throughout the prospectus.

ANSWER:

Page numbers have been included throughout the prospectus.

Outside Back Cover Page of the Prospectus

6.	Please remove from the first paragraph the statement: “or that we have referred you to” or explain supplementally.

ANSWER:

This statement has been removed from the outside back cover page of the prospectus.

Summary Information

7.	Disclose that the predecessor company, 51142 Inc., was a blank check company.

ANSWER:

This section of the registration statement has been revised to disclose that the Company’s predecessor company, 51142, Inc. was a blank check company.

Please clarify the transaction(s) that resulted in your acquiring Signet Entertainment Corp. The first paragraph indicates that Signet acquired all of the common stock of 51142 for $36,000 cash. The second paragraph indicates that the company (Signet International Holdings, formerly 51142 Inc.) acquired all of the issued and outstanding preferred and common stock of Signet Entertainment Corp. for a total of 3,421,000 shares of common stock and 5 million shares of preferred stock. Elsewhere in the prospectus, the disclosure indicates 2,118,000 shares of common stock were issued in the share exchange. Please clarify the series of transactions and the reason(s) for each. Disclose the material terms of these transactions. Reconcile the disclosure throughout the prospectus.

ANSWER:

The Company is not registering all 3,421,000 shares of common stock issued pursuant to the acquisition of Signet Entertainment Corp. Rather, the Company is registering only 2,118,000 of such shares. Therefore, the disclosure regarding 2,118,000 shares appears in the “Selling Security Holders” section because this is the number of shares that were issued pursuant to the share exchange that are being registered in this registration statement.

The reasons for the acquisitions are as follows: Signet Entertainment Corp. purchased all of the issued and outstanding shares of 51142 for purposes of acquiring a reporting company. Next, the Company entered into the share exchange with Signet Entertainment Corp. in order to acquire Signet Entertainment Corp. as a wholly-owned operating subsidiary of the Company. Thus, the Company is the publicly reporting holding company of the wholly-owned, operating subsidiary,

We note the statement that your network “will cover major Poker and Blackjack tournaments as well as other major high stakes casino games.” Please disclose whether you have entered into any agreements that will provide you will the ability to air these major tournaments. We may have further comment.

ANSWER:

This section of the registration statement has been revised to disclose that neither the Company nor its partner, Triple Play, have made formal arrangements with any other domestic or foreign production company to uplink or to receive any programming nor any agreement with any casino business or entity, nor any agreements to air any tournaments.

10.	Explain the statement that the network will cover other major sports events “via satellite and cable.” Will the Poker and other casino tournaments not also be covered by satellite and cable?

ANSWER:

This section of the registration statement has been revised to disclose that the Company will cover all events via satellite and cable, including poker and other casino tournaments once satellite and cable contracts have been executed

11.	Explain the reference to “selected global events which have a sports and entertainment format.”

ANSWER:

This section of the registration statement has been revised to disclose that “selected global events which have a sports and entertainment format” include: sports awards ceremonies; entertainment award ceremonies; celebrity sports events; celebrity gaming events; and other interesting and newsworthy events, foreign and domestic, the Company believes will appeal to its viewers.

12.	Clarify that you have not commenced operations, that you need additional capital to commence operations, there is no guarantee you will generate any revenues and that the independent accountants have expressed substantial doubt about the company’s ability to continue as a going concern.

ANSWER:

This section of the registration statement has been amended to disclose that the Company needs capital to commence operations, that there is no guarantee the Company will generate any revenues and that the independent accountants have expressed substantial doubt about the Company’s ability to continue as a going concern.

13.	We note the disclosure about how you will generate revenues. Given the current development stage of the company, make clear there is no guarantee you will generate any revenues.

ANSWER:

This section of the registration statement has been amended to disclose that there is no guarantee the Company will generate any revenues.

14.	Explain what LPTV stations are. Also, clarify whether you have entered into any negotiations or agreements, preliminary or otherwise, to purchase such stations. Lastly, remove the statement that “several LPTV stations broadcast in excess of 1,000,000 TV Households.”

ANSWER:

This section of the registration statement has been revised to explain what LPTV stations are and that the company has not entered into any negotiations or agreements, preliminary or otherwise, to purchase or otherwise acquire such stations. Furthermore, the statement that “several LPTV stations broadcast in excess of 1,000,000 TV Households” has been removed from the registration statement.

Risk Factors

15.	Remove the reference to other filings in the intro to the risk factors.

ANSWER:

Reference to other filings has been removed from the intro to the risk factors.

16.	Explain the reference in risk factor one to expanding or maintaining your operations, in light of the fact that you have not yet commenced operations.

ANSWER:

Reference to “maintaining our operations” has been removed from this risk factor.

17.	Add risk factors discussing your lack of an operating history, the operating losses to date and the going concern.

ANSWER:

This section has been revised to include risk factors discussing the Company’s lack of an operating history, the operating losses to date, and the going concern.

18.	Please include in the subheading of the third and fourth risk factors the risk to the company and/or investors.

ANSWER:

The subheadings in the third and fourth risk factor have been revised to disclose the risks poses to the Company and/or investors.

19.

The subheading to risk factor two, the inability to hire and retain key personnel, does not reflect the risk discussed in the narrative, the dependence upon your key employee, Mr. Letiziano. This risk is already covered in risk factor five. Please revise risk factor two to specifically discuss the risk referred to in the subheading and focus on the impact or risk to your company.

ANSWER:

This risk factor has been amended to reflect that failure to hire and retain skilled personnel could require the Company to diminish or suspend its developmental strategy.

20.	Explain the “Acquisition” referred to in risk factor three.

ANSWER:

This disclosure was made in error and therefore removed from the registration statement. The Company has not acquired an FCC license.

21.	We note the statements in numerous risk factors that the risk will “affect,” “adversely affect,” or “impact” your business. Please revise to remove such generic disclosure and state the specific risk to the company and/or investors.

ANSWER:

This registration statement has been amended to more specifically state the risks to the Company and investors.

22.	Revise the subheading to risk factor seven to clarify that there is currently no public market.

ANSWER:

This risk factor has been revised to clarify that there is currently no public market for the Company’s securities.

23.	Risk factors eight, nine and eleven are generic risks and should be removed. Relocate the disclosure in risk factor eleven relating to penny stock to later in the prospectus.

ANSWER:

The registration statement has been revised to remove risk factors eight, nine, and eleven. The section “Penny Stock Considerations” addresses the issues raised in former risk factor eleven.

Selling Security Holders

24.	Identify the control person(s) for those selling shareholders that are entities.

ANSWER:

The registration statement has been revised to identify the control person(s) for those selling shareholders that are entities.

25.	Please disclose how each of the selling shareholders obtained his or her stock.

ANSWER:

The registration statement has been revised to disclose how each shareholder received the shares being registered.

26.	Disclose any relationship between the selling shareholders.

ANSWER:

The registration statement has been revised to disclose any relationship between the selling shareholders.

27.	Clarify whether Mr. Letiziano is a broker-dealer or affiliate of a broker-dealer.

ANSWER:

The registration statement has been revised to clarify that Mr. Letiziano is not a broker-dealer.

28.	Please disclose how you propose to reflect any changes in selling security holders.

ANSWER:

The registration statement has been amended to disclose that “absent circumstances indicating that the change is material, the change may be reflected by the filing of a Rule 424(b) prospectus supplement describing the change and setting forth the information required by Item 507 of Regulation S-B. This assumes the change does not involve increasing the number of shares or dollar amount registered.”

29.	We note the shares of Mr. Freeman included in the selling shareholders table. Disclose how Mr. Freeman received these shares. We may have further comment.

ANSWER:

This section of the registration statement has been revised to disclose that Mr. Freeman Mr Freeman is a member of the Triple Play Media Management team, and that he received his shares pursuant to the share exchange between the Company and Signet Entertainment Corp. Mr. Freeman originally received 50,000 of such shares from Signet Entertainment Corporation pursuant to the agreement with Triple Play. The remaining 1,000 shares were purchased pursuant to Signet Entertainment Corporation’s private placement in exchange for cash consideration of $0.01 for an aggregate of $10.

Plan of Distribution

30.

Please disclose that the selling shareholders and any broker-dealers that act in connection with the sale of shares may be deemed to be “underwriters” within the meaning of Section 2(11) of the Securities Act, and any commissions received by such broker-dealers and any profit on the resale of shares sold by them while acting as principals might be deemed to be underwriting discounts or commissions under the Securities Act. Also, discuss the impact of Regulation M upon the selling shareholder offering.

ANSWER:

The registration statement has been amended to in accord with the above.

Directors, Executive Officers, Promoters and Control Persons

31.	Remove the promotional disclosure regarding Ringside International Broadcast Corporation.

ANSWER:

The promotional disclosure regarding Ringside International Broadcast Corporation has been removed.

32.	Disclose the amount and percent of time Mr. Letiziano devotes to your company.

ANSWER:

This section of the registration statement has been revised to disclose that Mr. Letiziano devotes 100% of his time to the Company

33.	Please revise this section, and disclosure throughout the prospectus, to avoid references to current “officers” and “directors,” since the company has only one officer and director.

ANSWER:

The registration statement has been revised to avoid references to current “officers” and “directors.”

34.	Please describe in greater detail Mr. Letiziano’s current work as an “international monetarist.”

ANSWER:

This section of the registration statement has been revised to disclose that Mr. Letiziano no longer is an “international monetarist.”

Security Ownership of Certain Beneficial Owners and Management

35.	Revise the ownership table to attribute ownership of the shares held by spouses to the corresponding beneficial owners. Refer to Securities Act Release No. 33-4819 (“a person is regarded as the beneficial owner of securities held in the name of his or her spouse and their minor children”).

ANSWER:

None of the individuals listed in this table qualify as a beneficial owner under Securities Act Release No. 33-4819. Mr. Letiziano, Ms. Hillabrand, and Mr. Grad do not have any spouses or minor children that hold shares in the Company.

36.	It appears that Signet Entertainment Corp. is controlled by Mr. Letiziano and should be included in the amount listed in the beneficial ownership table. The nature of the ownership should be included in a footnote.

ANSWER:

This section of the registration statement has been revised to disclose that Mr. Letiziano is the beneficial owner of the 100,000 shares of the Company’s common stock owned by Signet Entertainment Corp.

37.	Please provide the address for each beneficial owner. The company’s address may only be used for officers and directors.

ANSWER:

This section has been amended to disclose the addresses of each beneficial owner.

38.	Please update the beneficial ownership table in light of the shares issued on June 30, 2006 pursuant to exhibit 10.3.

ANSWER:

Such shares have not yet been issued and therefore have not been included.

Description of Securities

39.	We note that 5 million shares of preferred stock are issued and outstanding. Please revise this section to clearly indicate the material rights of the preferred stock issued and outstanding. Consider whether the beneficial ownership table should be revised in light of these rights.

ANSWER:

This section has been revised to disclose that Holders of shares of preferred stock are entitled to ten votes for each share on all matters to be voted on by the stockholders. Holders of preferred stock do not have cumulative voting rights. Holders of preferred stock are entitled to share ratably in dividends, if any, as may be declared from time to time by the Board of Directors in its discretion from funds legally available therefore. In the event of a liquidation, dissolution or winding up of the Company, the holders of preferred stock are entitled to share pro rata all assets remaining after payment in full of all liabilities. All of the outstanding shares of preferred stock are fully paid and non-assessable. Holders of preferred stock have no preemptive rights to purchase our preferred stock. There are no conversion or redemption rights or sinking fund provisions with respect to the preferred stock.

Business of Issuer

40.	Please state if true, that you are not a blank check company, as defined by Rule 419 and that you will not enter into a business combination.

ANSWER:

The registration statement has been revised to disclose that it is the Company’s opinion that it is not a blank check company as defined by Rule 419 and that, although a part of the Company’s business plan includes the acquisition of other entities, this is not the Company’s primary business and the Company may never complete any such acquisition. Any such acquisition would be contemplated only so far as such acquisition would further the Company’s business plan of launching a television broadcasting company. The Company currently has no intention to enter into any acquisition that requires Mr. Letiziano, the Company’s sole officer and director, to give up voting control of the Company’s stock or requires his resignation as the Company’s officer or director. In the event the Company acquires other entities in the future, Mr. Letiziano will maintain his ownership interest as well as his positions with the Company as full-time Chief Executive Officer and majority stockholder.

41.	We note the disclosure that you issued 3,421,000 shares of common stock and 5 million shares of preferred stock in the stock purchase agreement. Exhibit 2.2 does not refer to the 5 million shares of preferred stock. Please advise.

ANSWER:

The exhibit filed with the initial registration statement was included in error. The correct exhibit is filed with this amended registration statement

42.

Disclose the material terms of the agreements with Triple Play Media and Big Vision. For instance, we note that the agreement with Triple Play was in 2002 and that at the time of the agreement Triple Play was “a corporation to be formed.” Also, it appears that the agreement with Triple Play was with a significant shareholder of SIG. Please disclose.

ANSWER:

This section of the registration statement has been revised to disclose the material terms of the Triple Play and Big Vision agreements.

43.

We note that the agreement with Triple Play was entered into on September 23, 2002. SIG was not incorporated until October 17, 2003. Please explain whether there were any predecessors to SIG. If so, disclose the material terms as required by Item 101(a) of Regulation S-B. We may have further comment.

ANSWER:

The date was incorrectly entered and has since been corrected. Please reference the updated exhibit filed in conjunction with this amendment to the Form SB-2.

44.	Explain the reference to Triple Play providing programming content. The management agreement filed as exhibit 10.1 does not provide for programming.

	ANSWER:	The registration statement has been revised to disclose that Triple Play will produce television shows (programs) in the gaming and entertainment genre. Triple Play will also negotiate with rights-holders of old re-run television shows and provide these shows for additional programming.
45.	We note the $50,000 signing bonus to Mr. Grad, the guaranteed payment of $200,000 per year to Mr. Grad, moving and relocation costs and other benefits. Please disclose.

ANSWER:

The registration statement has been revised to disclose the consideration paid to Mr. Grad.

46.	Explain the reference to “most favored nation” basis.

ANSWER:

The registration statement has been revised to disclose that “Most favored nation” basis is a term used in the TV Production Industry to indicate that the rates charged by producers (in this case Big Vision) will be below fair-market rates, or at “wholesale” costs.

47.	Disclose the material terms of the April 13, 2006 agreement with Freehawk Productions.

ANSWER:

The registration statement has been revised to disclose that the Company’s agreement with FreeHawk dated April 13, 2006 provides for the purchase by the Company of the exclusive rights to 20 half-hour TV screen plays each with an additional 13 episodes. FreeHawk will receive $450,000 in cash and 550,000 shares of the Company’s common stock over a minimum of 36 months payments to be made subject to delivery of the screen plays as scheduled by the Company.

48.	Most of the programming purchased from Freehawk does not appear to fall within the gaming and sporting industry. Please discuss and explain the reason for the agreement. We may have further comment.

ANSWER:

The registration statement has been revised to disclose that FreeHawk has been creating and producing original programming (Drama, Comedy, Children and Reality shows) for the 25 years. It is management’s opinion that this content will enable Signet to appeal to a wider audience.

49.	Provide a detailed discussion of your proposed role in the business plan.

ANSWER:

The registration statement has been revised to disclose that Mr. Letiziano’s role is to implement the business plan. This will involve all the duties normally ascribed to a Chief Executive Officer for the day-to-day management of the business.

Programming

50.

Provide the basis for your belief that “this market is capable of producing substantial revenue based on the commercial advertising revenue potential of the hotel/casino/travel industry,” and that “the sales revenues from these industries alone, after the first year, will not only cover, operating costs and expenses thereafter, but also, within the next eighteen months, return sufficient revenue to pay for all of our initial capital expenditures” or remove.

ANSWER: