SecProbe.io

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Mail Stop 4561
									November 9, 2005

Mr. Kevin J. High
President
Cytation Corporation
251 Thames Street, No. 8
Bristol, RI 02809

      Re:	Cytation Corporation
		Form 10-KSB for Fiscal Year Ended December 31, 2004
		Form 10-QSB for Fiscal Quarter Ended March 31, 2005
		Form 10-QSB for Fiscal Quarter Ended June 30, 2005
		File No. 814-00675

Dear Mr. High:

      We have reviewed your above referenced filings and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and do not intend to
expand our review to other portions of your documents.  Where
indicated, we think you should revise your documents in response
to
these comments.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with information so we
may
better understand your disclosure.  After reviewing this
information,
we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-KSB for the Fiscal Year Ended December 31, 2004

Item 8. Changes in and Disagreements with Accountants on
Accounting
and Financial Disclosure

1. Pursuant to Item 307 of Regulation S-B, revise to disclose the
conclusions of your chief executive officer and chief financial
officer regarding the effectiveness of your disclosure controls
and
procedures as of the end of the period covered by the report.
2. Please revise to disclose changes in internal control over
financial reporting pursuant to Item 308(c) of Regulation S-B.

Financial Statements

Statements of Operations

3. Please advise us of the nature of the preferred stock dividend
earned of $206,324.  We did not note any preferred stock issued
and
outstanding during the periods presented based on the Statement of
Changes in Stockholders` Equity (Deficit).

Note 2.  Summary of Significant Accounting Policies

4. Please disclose to us how the revenue recognition criteria set
forth in SAB 101 and other accounting literature, as appropriate,
are
applied specifically to the recognition of revenue in your
business.

Note 8.  Investment/Non-Cash Income

5. With respect to the recording of revenues for services
performed
in exchange for securities of Solomon Technologies, Inc. and
Hydrogen
Technology Applications, Inc., please disclose to us the following
for each investment:
a) The period over which services were performed;
b) The amount of revenue recognized and in what period(s);
c) The amount of related costs of revenue incurred, the period(s)
in
which the costs were incurred and the period(s) in which such
expenses were recognized.
Finally, please explain the basis for you accounting treatment and
how you considered EITF 00-8 in accounting for these transactions.

6. We note your disclosure that your investments are carried at
cost
basis.  For each investment, please tell us how you determined the
initial value of the securities received in exchange for services,
how and with what frequency you evaluated such investments for
changes in the fair value, and where in the income statement such
unrealized gains and losses, if any, were recorded.  Finally,
please
explain how you considered SFAS 115 in accounting for these
securities.

7. Please address how you considered your right to receive 148,468
warrants of Hydrogen Technology Applications, Inc., as disclosed
in
the critical accounting policies section of MD&A, in determining
the
initial value or in subsequent adjustments to such value.

8. Please advise us of the following regarding the shares of
Solomon
Technologies, Inc. and Hydrogen Technology Applications, Inc.:
a) The method(s), quantity and dates of disposition of the shares;
b) The fair value of the shares on such dates;
c) The gain(loss) recognized on such dispositions, if any;
d) How such dispositions are recorded in the financial statements.
Please provide the requested information for the shares disposed
of
during 2004 as well as those disposed during the first two
quarters
of 2005.
9. Please explain how you applied the guidance in paragraph 18 of
APB
29 in accounting for your distribution of Solomon stock to your
shareholders.  Specifically, explain why you have not recorded a
gain
or loss on the transaction.  Also, please revise to classify
within
your accumulated deficit or explain your basis for classifying it
in
additional paid-in capital.

Item 13. Exhibits, Financial Statement Schedules, and Reports on
Form
8-K

10. Please revise the section 302 certifications filed to reflect
the
language exactly as set forth in Item 601(b)(31) of Regulation S-
B,
if such statements continue to be true considering the revised
wording and evaluation date as of the period end, rather than as
of a
date within 90 days of the filing.  Refer to Management`s Report
on
Internal Control over Financial Reporting and Certification of
Disclosure in Exchange Act Periodic Reports, SEC Release No. 33-
8238,
available on our website at <http://www.sec.gov/rules/final/33-
8238.htm> for guidance.  Please make conforming changes to the
Forms
10-QSB for the quarters ended March 31, 2005 and June 30, 2005.

Form 10-QSB for the Fiscal Quarter Ended March 31, 2005

Statements of Operations

11. Please disclose to us the nature of the gain on sale of
investment of $266,250 for the three months ended March 31, 2004.
We
note that this amount exceeds the gain for the year per the
statement
of operations in your Form 10-KSB for the year ended December 31,
2004.  In addition, please provide the same information for the
gain
on sale of investment reported for the three and six months ended
June 30, 2004 in your Form 10-QSB for the quarter ended June 30,
2005.

Form 10-QSB for the Fiscal Quarter Ended June 30, 2005

Statements of Operations

12. Please revise the statement of operations for the six months
ended June 30, 2004 so that it is mathematically accurate.
Note 3.  Equity Transactions

13. Please tell us how you accounted for each of the equity
transactions detailed in your footnote, including any expense
amounts
recorded in relation to the consideration received in exchange for
the issuance of the equity instruments.  Refer to 8-10 of SFAS
123.
In your response, please also address how you considered the
warrants
to purchase shares of Solomon common stock in recording such
transactions.

      As appropriate, please amend your filings and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please file your cover letter on EDGAR.
Please understand that we may have additional comments after
reviewing your amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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 comments, please
provide,
in writing, a statement from the company acknowledging that:

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

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* 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 Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      You may contact Amanda Sledge, Staff Accountant, at (202)
551-
3473 or the undersigned at (202) 551-3403 if you have questions.

								Sincerely,

      Steven Jacobs
      Accounting Branch Chief
Mr. Kevin J. High
Cytation Corporation
November 9, 2005
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