Larry O'Donnell, CPA, P.C.

Telephone (303) 745-4545                                2228 South Fraser Street
Fax (303)369-9384
                                                                          Unit I
Email  larryodonnellcpa@comcast.net
Aurora, Colorado    80014
www.larryodonnellcpa.com




November 5, 2010


SECURITIES AND EXCHANGE COMMISSION
Division of Corporation Finance
100 F Street, N.E., Mail Stop 7010
Washington, D.C. 20549

         Re:      Momentum Biofuels, Inc. (the "Company")
                  ---------------------------------------
                  Form 8-K Item 4.01 (the "Report")

Gentlemen:

         We have reviewed the above referenced  Report filed by the Company.  We
do not  disagree  with the  statements  made by the  Company  in the  Report and
authorize the Company to file a copy of this letter as an exhibit to the Report.



                                      /s/ Larry O'Donnell, CPA, PC
                                          -------------------------
                                          Larry O'Donnell, CPA, PC