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  of  the  Quarterly  Report  of  ValCom,  Inc.,  a Delaware
corporation  (the  "Company"), on Form 10-QSB for the period ending December 31,
2004,  as  filed  with the Securities and Exchange Commission on the date hereof
(the  "Report"),  I,  Tracey  Eland  ,  the  Company's  Secretary  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, and
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  15,  2005

               By:     /s/  Tracey  Eland
               ------------------
               Tracey  Eland
               Secretary  and  Principal
               Accounting  Officer


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