<SEC-DOCUMENT>0001165527-12-001114.txt : 20130617
<SEC-HEADER>0001165527-12-001114.hdr.sgml : 20130617
<ACCEPTANCE-DATETIME>20121023123707
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0001165527-12-001114
CONFORMED SUBMISSION TYPE:	CORRESP
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20121023

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			Earn-A-Car Inc.
		CENTRAL INDEX KEY:			0001486297
		STANDARD INDUSTRIAL CLASSIFICATION:	SERVICES-AUTO RENTAL & LEASING (NO DRIVERS) [7510]
		IRS NUMBER:				271320213
		STATE OF INCORPORATION:			NV
		FISCAL YEAR END:			0228

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		OFFICE 1 THE FALLS CENTRE
		STREET 2:		CORNER GREAT NORTH AND WEBB
		CITY:			NORTHMEAD, BENONI 1522
		STATE:			T3
		ZIP:			00000
		BUSINESS PHONE:		27-11-425-1666

	MAIL ADDRESS:	
		STREET 1:		OFFICE 1 THE FALLS CENTRE
		STREET 2:		CORNER GREAT NORTH AND WEBB
		CITY:			NORTHMEAD, BENONI 1522
		STATE:			T3
		ZIP:			00000

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	VICTORIA INTERNET SERVICES INC
		DATE OF NAME CHANGE:	20100304
</SEC-HEADER>
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
FRANK J. HARITON * ATTORNEY-AT-LAW
--------------------------------------------------------------------------------
1065 Dobbs Ferry Road * White Plains * New York 10607 *
(Tel)(914)674-4373 * (Fax)(914)693-2963 * (e-mail) hariton@sprynet.com


                                                                October 23, 2012

Loan Lauren P. Nguyen,
Special Counsel
Division of Corporation Finance
Securities and Exchange Commission
Washington, D.C. 20549

     Re: Earn-A-Car Inc. (f/k/a Victoria Internet Services, Inc.)
         Amendment Number 2 to Current Report on Form 8-K
         File No. 333-165391

Dear Ms. Nguyen:

     I am securities counsel to Earn-A-Car Inc. (f/k/a Victoria Internet
Services, Inc.) (the "Company") and am writing to advise you that the Company's
response to the staff's letter, dated September 14, 2012, will be filed on EDGAR
no later than November 16, 2012. The delay in the response is principally the
result of my travel schedule and the Company's limited staff. We will be
contacting the staff next week for clarifications of certain points in the staff
letter.

     If you require anything further, do not hesitate to contact me.

                                          Very truly yours,


                                          /s/ Frank J. Hariton
                                          --------------------------------
                                          Frank J. Hariton
<PAGE>
October 23, 2012

Loan Lauren P. Nguyen,
Special Counsel
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.W.
Washington, D.C. 20549

     Re: Earn-A-Car Inc. (formerly known as Victoria Internet Services, Inc.)
         Amendment No. 2 to Form 8-K
         Filed August 29, 2012
         File No. 333-165391

Dear Ms. Nguyen:

     Earn-A-Car Inc. (the "Company"), hereby acknowledges, in connection with
its response to the your comments on its Form 8-K referenced above and all
amendments thereto that:

     *    the Company is responsible for the adequacy and accuracy of the
          disclosure in its filings;

     *    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

     *    the Company 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.

Very truly yours,

Earn-A-Car Inc.


/s/ John Storey
-----------------------------
By: John Storey, CEO
</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>