SecProbe.io

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<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>kl10044_corresp.txt
<DESCRIPTION>CORRESPONDENCE
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                       KRAMER LEVIN NAFTALIS & FRANKEL LLP

                                919 THIRD AVENUE

                           NEW YORK, N.Y. 10022 - 3852

FLORENCE R. LIU
ASSOCIATE                                                                  PARIS
TEL (212) 715-7568                                        47, AVENUE HOCHE 75008
FAX (212) 715-8206                                        TEL (33-1) 44 09 46 00
fliu@kramerlevin.com                                      FAX (33-1) 44 09 46 01

                                                October 20, 2004

United States Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C.  20549-0406
Attn:  Melissa Walsh

Re:   Wireless Frontier Internet, Inc.
      Form 8-K filed October 6, 2004
      File No. 000-08281

Dear Ms. Walsh:

      On behalf of our client, Wireless Frontier Internet, Inc. (the "Company"),
we provide the Company's responses to the comments of the Staff (the "Staff") of
the Division of Corporation Finance of the Securities and Exchange Commission
(the "Commission") in its letter to the Company, dated October 12, 2004, with
respect to the Current Report on Form 8-K of the Company (the "Form 8-K"), which
was filed with the Commission on October 6, 2004.

      For the Staff's convenience, the Staff's comments have been stated below
in their entirety, in bold, with the responses to a particular comment set out
immediately under the comment.

      1.    Staff Comment: The disclosure in the first paragraph indicates that
            your former accountant resigned on September 30, 2004. Accordingly,
            revise the disclosure regarding disagreements and reportable events
            to specifically refer to the two most recent fiscal years and
            subsequent interim period through September 30, 2004. Refer to Item
            304(a)(1)(iv) of Regulation S-B.

            Company Response: The Form 8-K has been revised in response to the
            Staff's comments. Please see the revisions on page 1 of Amendment
            No. 1 to the Form 8-K.

      2.    Staff Comment: Revise your disclosure with respect to the engagement
            of a new accountant to indicate whether the new accountant was
            consulted during the two most recent fiscal years or subsequent
            interim period through the

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KRAMER LEVIN NAFTALIS & FRANKEL LLP

Ms. Melissa Walsh
United States Securities and Exchange Commission
October 20, 2004
Page 2

            date of engagement. Provide disclosures to comply with Item
            304(a)(2) of Regulation S-B.

            Company Response: The Form 8-K has been revised in response to the
            Staff's comments. Please see the revisions on page 1 of Amendment
            No. 1 to the Form 8-K.

      3.    Staff Comment: Within ten business days after the filing of the Form
            8-K report, or by October 20, 2004, please file a letter from your
            former accountant, indicating whether or not they agree with your
            disclosures in this Form 8-K and any revised statements made in your
            Form 8-K to the extent that you make changes to comply with our
            comments. Refer to Item 304(a)(3) of Regulation S-B.

            Company Response: The letter from Pollard-Kelley Auditing Services,
            Inc., in response to the Staff's comments, has been filed as an
            exhibit to Amendment No. 1 to the Form 8-K.

      4.    Staff Comment:
            -------------

            General
            -------

                  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 comment, please provide,
            in writing, a statement from the company acknowledging that:

                  o     the company is responsible for the adequacy and accuracy
                        of the disclosure in the filings;

                  o     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

                  o     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.

                  In addition, please be advised that the Division of
            Enforcement has access to all information you provide to the staff
            of the Division of

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KRAMER LEVIN NAFTALIS & FRANKEL LLP

Ms. Melissa Walsh
United States Securities and Exchange Commission
October 20, 2004
Page 3

            Corporation Finance in our review of your filing or in response to
            our comment on your filing.

            Company Response: The Company supplementally advises the Staff that
            the Company is responsible for the adequacy and accuracy of the
            disclosure in the filings that the Company makes with the Staff. In
            addition, the Company supplementally acknowledges to the Staff that
            any Staff comments or changes to disclosure in response to Staff
            comments in the Company's filings reviewed by the Staff do not
            foreclose the Commission from taking any action with respect to the
            filing. Furthermore, the Company supplementally acknowledges to the
            Staff that 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.

      If you have any questions with regard to these responses, need further
supplemental information or would like to discuss any of the matters covered in
this letter, please contact the undersigned at (212) 715-7568 or Ernest S.
Wechsler of this office at (212) 715-9211.

                                    Very truly yours,

                                    /s/ Florence R. Liu

cc:  Mr. Alex J. Gonzalez (Wireless Frontier)
     Mr. Kelly E. Simmons (Wireless Frontier)
     Ernest S. Wechsler, Esq. (Kramer Levin)

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