January 15, 2007

Mr. Dennis C. Hult
Staff Accountant
Securities and Exchange Commission
Washington, D.C. 20549

RE: Letter dated January 12, 2007

Dear Mr. Hult:

In response to the referenced letter please be advised of the following:

Form 8-K dated and filed January 9, 2007
- ----------------------------------------

Item 4(a)(1)(i), page 2
- -----------------------

1.  Please  revise the Form to state  whether  the former  accountant  resigned,
declined to stand for  re-election or was  dismissed,  and the specific date, as
required by Item  304(a)(l)(i)  of Regulation S-K. It is not sufficient to state
that "the  registrant  intended  to retain a  different  independent  accounting
firm", as that wording is unclear to a reader.

Answer  (The  Form  has been  revised  to state  that  the  Registrant's  Former
accountant  was  dismissed,  and the specific date of dismissal,  as required by
Item 304 (a)(1)(i) of Regulation S-B)

2.  The  disclosure   should  also  indicate  whether  the  board  of  directors
recommended   or  approved  the  decision  to  change   accountants.   See  Item
304(a)(l)(iv)(D).

Answer (The Form 8-K has been revised to indicate that the Registrant's board of
directors  participated in and approved the decision to dismiss the Registrant's
accountants.)

3. We note that the auditor's letter filed as Exhibit 1 is dated January 5, 2007
and indicates on that date they were notified of the dismissal- Please reconcile
this with disclosure made in paragraph  (a)(l)(i) of your report and the date of
the report, which should be the date of earliest event reported.

Answer (The  disclosure  made in paragraph  (a)(1)(i) and the date of the Report
have been revised to reconcile  with the auditors  letter filed as an Exhibit to
the Report)

4.  Please  have your  auditor  provide  you with an Exhibit  16 letter  stating
whether they agree with the  statements  made by the registrant in the Item 4.01
Form 8-K and, if not,  stating the respects in which it does not agree. See Item
304 (a)(3) of Regulation SB. The letter should be filed as Exhibit 16. Note: the
letter  filed as Exhibit 1 appears to be a SECPS letter which serves a different
purpose and is not  required  to be filed as an exhibit  with you Item 4.01 Form
8-K.



Page 2. Letter From SEC 1-12-2007

In connection with responding to our responses, Registrant acknowledges that:

1.  Registrant is responsible for the adequacy and accuracy of the disclosure in
the filing;

2. SEC 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  Registrant  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.

If you need any additional information please let us know.

Sincerely,

/s/ Scott A. Haire

Scott A. Haire,

President