SecProbe.io

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<TYPE>LETTER
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<FILENAME>filename1.txt
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Mail Stop 4561
									December 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 response letter dated November 20,
2005
and have the following additional comments.  As previously stated,
these comments require amendment to the referenced filings
previously
filed with the Commission.  In some of our comments, we ask you to
provide us with information so we may better understand your
disclosure.  After reviewing this information, we may raise
additional comments.

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

1. We have read your responses to prior comments three, ten,
twelve
and thirteen.  Please file an amended Form 10-KSB for the year
ended
December 31, 2004 and amended Forms 10-QSB for the quarters ended
March 31, 2005 and June 30, 2005 that incorporate your proposed
revisions.

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

2. We have read your response to prior comments one and two.
Please
revise to make reference to the rules defining disclosure controls
and procedures, Exchange Act Rules 13a-15(e) and 15d-15(e), to
disclose the officers` conclusions as of the end of the period
covered by the report, and to state whether your officers
determined
that such disclosures controls and procedures were effective.
Also
revise to clearly state whether any significant deficiencies or
material weaknesses existed, or remove the sentence regarding
corrective actions if none existed.

Financial Statements

Note 8.  Investment/Non-Cash Income
3. Related to prior comment four, please expand upon your revenue
recognition policy to explain how your contracts are priced and
how
you measure the portion of total contract price that is earned at
a
point in time.  Please summarize the terms of your consulting
agreements that support your policy.  In addition, please explain
how
you allocate related costs such as consulting fees over the
service
period.  Based upon your historical statements of operations, your
margins do not indicate a ratable allocation or reasonable
methodology.  Please tell us and disclose the relevant accounting
literature you have relied upon.  Finally, please tell us how you
evaluated the indicators in EITF 99-19 in determining that
consulting
revenues and fees should be presented on a gross basis.

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

Note 7 - Subsequent Events

4. Please revise to reflect the 2-for-1 stock dividend declared on
November 14, 2005 in determining your weighted average shares
outstanding and net income (loss) per share amounts.  Refer to
paragraph 54 of SFAS 128.

      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.

      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
December 9, 2005
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