August 19, 2005

Via Facsimile and U.S. Mail 212-868-4414

David Silverman
Treasurer, Chief Financial Officer
Scores Holding Company, Inc.
533-535 West 27th Street
New York, NY  10001

	RE:	  Scores Holding Company, Inc.
  File No. 0-16665
        Form 10-KSB for the fiscal year ended December 31, 2004


Dear Mr. Silverman:

      We have reviewed the above referenced filing and have the
following comments.  We have limited our review to the financial
statements and related disclosures included within this document.
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 filings.

      Please expand or revise your disclosure as requested.  If
you
disagree, we will consider your explanation as to why our comments
are inapplicable or a revision is unnecessary.  In some of our
comments, we may ask you to provide us with additional information
so
we may better understand your disclosure.  Please be as detailed
as
necessary in your explanations.  We look forward to working with
you
in these respects and welcome any questions you may have about any
aspects of our review.


Form 10-KSB for the fiscal year ended December 31, 2004

Note 4:  Related Party Transactions, page F-14

1. We note that your receivable balance represents a significant
portion of the revenue recorded in 2004.  Tell us why you believe
it
was appropriate to initially recognize the revenue underlying
these
receivables, as collectibility should be reasonably assured prior
to
recognition.  Also, tell us your basis for determining that the
amount recorded as of December 31, 2004 is collectible.

2. We note that you have only collected $40,000 in cash on the
promissory note from GoWest.  Based upon the payment schedule on
page
F-14, this note appears delinquent.  Provide us a collectibility
analysis of this note as of December 31, 2004.

Other

3. We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.



*    *    *    *

      Please file your response to our comments via EDGAR within
fifteen business days from the date of this letter.  Please
understand that we may have additional comments after reviewing
your
response.  You may contact Theresa Messinese at 202-551-3307 or
the
undersigned at 202-551-3812 with any questions.

								Sincerely,



								Michael Fay
								Branch Chief




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Scores Holding Company, Inc.
August 19, 2005
Page 3