Mail Stop 4561


      February 24, 2006



Mitchell Johnson
President
InfraBlue (US) Inc.
Suite 5.15, 130 Shaftsbury Avenue
London, England W1D 5EU

Re:	InfraBlue (US) Inc.
      Registration Statement on Form SB-2
      Amended on February 10, 2006
      File No. 333-130403

Dear Mr. Johnson:

      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.

General
1. We note your response to Comment 2, but are unable to locate
the
ARC Group Research dated November 4, 2004. Please provide us with
a
copy of the cited source.



State Securities Laws, page 18
2. We note your response to Comment 21. Please revise the cover
page,
summary and throughout to indicate that you do not presently plan
to
register or qualify the common shares pursuant to state law and
the
consequences to investors.  Further, please revise the risk factor
heading as well as the disclosure to reflect the fact that you do
not
intend to register or qualify the shares in any state and revise
the
heading and the discussion to disclose the risks associated with
your
intention not to register or qualify the shares in any state.

Administration Contact with Azuracle - page 27
3. We note your response to Comment 25, but are unable to
determine
where you have revised this section of your document in response
to
the comment. Please revise or advise.

Certain Relationships and Related Transactions - page 41
4. We note your response to Comment 30, and your statement in
paragraph three that the determination of the number of shares
issued
for the intellectual property assets "was determined by arms
length
negotiation with the Keydata Partnership." Note 8.d. to the
financial
statements, however, indicates that the acquisition of the
intellectual property assets was a "related party transaction"
Please
advise to address the apparent discrepancy. We note that the
purchase
agreement between the company and Public Lock was dated November
1,
2005, and that the purchase agreement between Public Lock and
Keydata
was likewise dated November 1, 2005.

Consolidated Financial Statements, page F-1
5. Please update your financial statements as required by Item
310(g)
of Regulation S-B.

Consolidated Statements of Cash Flows, page F-6
6. We note your revisions in response to comment 33.  It does not
appear that the $9,294 characterized as "Due to Tomi Holdings,
Inc."
would have resulted in a cash inflow on a consolidated basis.  In
addition, it appears that the change in consolidated accrued
liabilities for the year ended September 30, 2005 was $33,021
rather
than $22,994.  Please advise.





Note 2 - Significant Accounting Policies
j) Revenue Recognition, page F-10
7. We note your response to comment 35.  Please specifically tell
us
how you considered paragraphs 56-62 of SOP 97-2 when determining
whether to allocate a portion of the revenue from the IRMA device
sales to the upgrades and customer support offered to customers
subsequent to sales.

Note 11 - Subsequent Events, page F-18
8. We note your response to comment 37.  Please disclose the value
of
the aggregate shares issued to PublicLock, Inc. in exchange for
the
Infrablue Technology based upon your proposed offering price.

Item 28. - Undertakings
9. We note your response to Comment 40. Please revise to include
the
undertakings pursuant to Item 512(g) of Regulation S-B as recently
amended.


      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.

	You may contact Jessica Barberich, Accountant, at (202) 551-
3782
or Kristi Beshears, Senior Accountant, at (202) 551-3429 if you
have
questions regarding comments on the financial statements and
related
matters.  Please contact Paul Fischer, Staff Attorney, at (202)
551-
3415 or the undersigned at (202) 551-3780 with any other
questions.


      Sincerely,



      Elaine Wolff
      Branch Chief



cc:	Michael H. Taylor, Esq. (via facsimile)



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Infrablue (US) Inc.
February 24, 2006
Page 4