EXHIBIT 31.2

                           CERTIFICATIONS PURSUANT TO
                         RULES 13A-14 AND 15D-14 OF THE
                  SECURITIES EXCHANGE ACT OF 1934, AS AMENDED,
                             AS ADOPTED PURSUANT TO

SECTION  302  OF  THE  SARBANES-OXLEY  ACT  OF  2002

In  connection  with  the  Annual Report of ValCom, Inc., a Delaware corporation
(the  "Company"),  on  Form  10-KSB for the period ending September 30, 2004, as
filed  with  the  Securities  and  Exchange  Commission  on the date hereof (the
"Report"),  I,  Tracey  Eland, the Company's Secretary, Controller and principal
accounting  officer  (the "Officer"), certify, pursuant to Rule 13a-14 or 15d-14
of  the  Securities  Exchange  Act  of  1934,  as  amended,  that:

     (1) The Officer has reviewed the Report.

     (2) Based on the Officer's knowledge, the Report does not contain any
untrue statement of a material fact or omit to state a material fact necessary
to make the statements made, in light of the circumstances under which such
statements were made, not misleading with respect to the period covered by the
Report.

     (3) Based on the Officer's knowledge, the financial statements and other
financial information included in the Report fairly present in all material
respects the Company's financial condition and results of operations as of, and
for, the periods presented in the Report.

     (4) The Officer and the other certifying officer:

          (a) Are responsible for establishing and maintaining "disclosure
     controls and procedures," as that term is defined by the Securities and
     Exchange Commission, for the Company.

          (b) Have designed such disclosure controls and procedures to ensure
     that material information relating to the Company is made known to them,
     particularly during the period in which the periodic Report is being
     prepared.

          (c) Have evaluated the effectiveness of the Company's disclosure
     controls and procedures within 90 days prior to the filing date of the
     Report.

          (d) Have presented in the Report their conclusions about the
     effectiveness of the disclosure controls and procedures based on the
     required evaluation as of that date.

     (5) The Officer and the other certifying officer have disclosed to the
Company's auditors and audit committee of the board of directors (or persons
fulfilling the equivalent function):

          (a) All significant deficiencies in the design or operation of
     internal controls, as that term is defined by the Securities and Exchange
     Commission, which could adversely affect the Company's ability to record,
     process, summarize and report financial data and have identified for the
     Company's auditors any material weaknesses in internal controls; and

          (b) Any fraud, whether or not material, that involves management or
     other employees who have a significant role in the Company's internal
     controls.

     (6) The Officer and the other certifying officer have indicated in the
Report whether or not there were significant changes in internal controls or in
other factors that could significantly affect internal controls subsequent to
the date of their evaluation, including any corrective actions with regard to
significant deficiencies and material weaknesses.

                              Dated: March 14, 2005

                              By: /s/ Tracey Eland
                            -----------------------
                                  Tracey Eland
                                  Secretary, Controller and
                                  principal accounting officer