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Cytation Corporation

251 Thames Street, No. 8
PO Box 809
Bristol, RI
02809

Richard A. Fisher
Chairman and General Counsel

November 20, 2005

Mr. Steven Jacobs
Accounting Branch
Chief
Securities and Exchange Commission
Division of Corporate
Finance
Mail Stop 4561
450 Fifth Street, NW
Washington, DC 20549

Re:   Cytation
Corporation
        Form 10KSB 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. Jacobs:

Reference is hereby made to the comment letter of Steve Jacobs,
Accounting Branch Chief of the staff (the "Staff") of the Division of Corporate
Finance of the Securities and Exchange Commission ("SEC"), dated November 9,
2005, addressed to Kevin J. High, President of Cytation Corporation (the
"Company"). Your comments have been inserted in this letter, and our responses
appear immediately below.

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,
revised 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.

Item 8A (below) will be is added to the Form 10KSB upon
amendment.

ITEM 8A: CONTROLS AND PROCEDURES

"The Company's principal executive officer and principal
financial officer have, within 90 days of the filing date of this annual report,
evaluated the effectiveness of the Company's disclosure controls and procedures
(as defined in Exchange Act Rules 13a - 14(c)) and have determined that such
disclosure controls and procedures are adequate. There have been no significant
changes in the Company's internal controls or in other factors that could
significantly affect such internal controls since the date of evaluation.
Accordingly, no corrective actions have been taken with regard to significant
deficiencies or material weaknesses."

2.  Please revise to disclose changes in internal
control over financial reporting pursuant to Item 308(c) of Regulation S-B.

Item 8A (below) will be is added to the Form 10KSB upon
amendment.

ITEM 8A: CONTROLS AND PROCEDURES

"The Company's principal executive officer and principal
financial officer have, within 90 days of the filing date of this annual report,
evaluated the effectiveness of the Company's disclosure controls and procedures
(as defined in Exchange Act Rules 13a - 14(c)) and have determined that such
disclosure controls and procedures are adequate. There have been no significant
changes in the Company's internal controls or in other factors that could
significantly affect such internal controls since the date of evaluation.
Accordingly, no corrective actions have been taken with regard to significant
deficiencies or material weaknesses."

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).

The preferred stock dividend earned of $206,324 was incorrectly
included on the Statement of Operations for the year ended December 31, 2003. We
have removed this erroneous reference to "Preferred Stock Dividend Earned" on
the revised Statement of Operations. We have also deleted on the Statements of
Operations in the Financial Statements and the Management' Discussion and
Analysis the reference immediately following to "Net Income (Loss) Attributable
to Common Shares" as unnecessary. For 2003, the "Net Income (Loss) Per Share -
Basic" will be changed to $4.50 from $3.72 and "Net Income (Loss) Per Share -
Diluted" to $4.11 from $3.40.

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.

Revised Note 2e (below) will be incorporated into to the
Financial Statements upon amendment.

e.  Revenue Recognition - Revenue is not recognized until it is
realized or realizable and earned. Consulting revenue is considered to have been
earned when the services are rendered. The Company's consulting contracts are
generally short-term in nature (usually to be performed with a one year period)
with substantial services provided up-front.

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;

Cytation performed services for Solomon during the period May
2003 through January of 2004. Cytation performed services for Hydrogen during
the period May 2004 through February 2005.

(b)  The amount of revenue recognized and in what
period(s);

See table, below.

(c)  The amount of related costs of revenue incurred,
the period(s) in which the costs were incurred and the periods(s) in which such
expenses were recognized.

See table, below.

      (b)

      (c)

      Period

      Amount

      Amount

      Period

      Solomon Technologies, Inc.  ("Solomon")

2003

1,351,178 (i)

5,126

2003

      2004

      36,900

      720,204 (ii)

      2004

      Hydrogen Technology
Applications ("Hydrogen")

2004

198,468 (iii)

16,851

2004

      2005

      49,114 (iv)

(i)   Included non-cash revenue (663,089 shares
of Solomon common stock) of $1,326,178.
(ii)   Included
non-cash expenses of $712,750 (transfer of Solomon shares to various
consultants).
(iii)  Included non-cash revenue (593,873 shares of
Hydrogen's common stock) of $148,468.
(iv)  Non-cash revenue -
Additional 196,456 shares of Hydrogen's common stock received on September 1,
2005 in connection with settlement agreement with HTA.

Finally, please explain the basis for your accounting treatment
and how you considered EITF 00-8 in accounting for these
transactions.

In according with EITF 00-8, Accounting by a Grantee for an
Equity Instrument to Be Received in Conjunction with Providing Goods or
Services, the equity instruments that the Company received in conjunction
with its services were measured at fair value on the date the parties reached
the "Performance Commitment", as defined in EITF 00-8.

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.

Solomon Shares

The Company assisted Solomon in preparing to become a reporting
company under the Securities Exchange Act of 1934. For these services, Solomon
issued to the Company restricted shares of its common stock. In the absence of a
readily determined fair value for the Solomon common stock, the Company reviewed
the unaudited financial statements of Solomon and the historical sales of
Solomon stock. Solomon had sold for cash in several arm's length transactions
restricted shares of common stock shortly before the issuance of common stock to
the Company at $1.00 per share ($2.00 per share adjusted for a 1-for-2 reverse
split). In the absence of a readily determined fair value for the Solomon common
stock, this was the basis for the Company taking into income the shares of
common stock of Solomon that it received at $2.00 per share (post 1-for-2
reverse split).

This investment was carried at cost until March 2004, when
Solomon's common stock started trading publicly. At that time, the Company
classified the Solomon shares as "Available for Sale" securities. As a result,
the Solomon shares were carried at market value with the unrealized gains and
losses were recorded as "Other Comprehensive Income" on the Balance Sheet in
accordance with SFAS 115, Accounting for Certain Investments in Debt and
Equity Securities. As of December 31, 2004, all of the Solomon shares were
either sold or distributed.

No value was ascribed to the Solomon warrants in 2003 because
there was no written warrant agreement, the exercise price could not be
determined at that time and the term of the warrant was uncertain. In March
2004, the stock purchase warrant was issued, the exercise price was established
at $3.15 per share and the term of the warrant was fixed at five years expiring
in January 2009 with an anti-dilution provision. On September 1, 2005, after
several anti-dilution adjustments, the number of warrants is increased to
242,246 and the exercise price decreased to $1.72 per share. Also on September
1, 2005, the Company distributed 220,246 warrants to two consultants and
transferred 20,000 warrants to an investor in connection with his purchase of
23,500 shares of the Company's common stock. These warrants are valued at
$0.1317 per share based on the Black-Scholes option model. As a result, the
Company recorded a gain on sale and distribution of investment of $31,902, of
which $29,268 was recorded as consulting fees and $2,634 as a reduction of
paid-in capital.

Hydrogen Shares

In July 2004, the Company received 593,873 restricted shares of
Hydrogen's common stock in exchange for the consulting services provided and to
be provided. In the absence of a readily determined fair value for the Hydrogen
stock, the Company reviewed the unaudited financial statements of Hydrogen and
the historical sales of Hydrogen stock. The latest sale of Hydrogen stock
occurred on April 15, 2004, at which time Hydrogen sold 50,000 shares of its
common stock at $0.25 per shares in cash in an arm's length transaction. This
value was used for the initial value of the Hydrogen shares. This investment was
carried at cost and evaluated for impairment quarterly by management. Because
this investment at all times did not have a readily determined fair value, its
accounting treatment is not within the scope of SFAS 115, Accounting for
Certain Investments in Debt and Equity Securities. On September 1, 2005, the
Company entered into a settlement agreement with Hydrogen, whereby Hydrogen
issued additional 196,456 of its common stock to the Company. The additional
shares were valued at $0.25 per share and such shares were distributed to two
consultants simultaneously. Non-cash income and non-cash consulting fees of
$49,114 was recorded for the quarter ended September 30, 2005.

American Radio Empire, Inc. ("ARE")

In August 2004, the Company received 500,000 restricted shares
of ARE's common stock for consulting service provided. ARE is a start-up,
development stage enterprise with no revenue, and it had never sold any of its
common stock. It is owned and controlled by one person. This investment was
initially valued at $5,000, the par value of the common stock, which management
believes is approximately the fair value of the shares. At December 31, 2004,
management evaluated the value and concluded that $5,000 continued to be the
fair value for this investment. In the first quarter of 2005, the Company
retuned all of these shares to ARE and entered into a mutual release agreement.
Because this investment at all times did not have a readily determined fair
value, its accounting treatment is not within the scope of SFAS 115,
Accounting for Certain Investments in Debt and Equity
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.

At the time the Company had the right to receive 148,468
warrants of Hydrogen Technology Applications, Inc. ("Hydrogen Warrant"), no
value has been assigned on the Hydrogen Warrant because the exercise price and
the date of exercisable would not be determined. On September 1, 2005, Hydrogen
and the Company entered into a settlement agreement, whereby the exercise price
was fixed on $1.00 per share and additional 49,114 warrants were granted to the
Company. In addition, all warrants became exercisable on September 1, 2005 for a
ten year period. Simultaneously, the Company distributed all these warrants to
two consultants. Based on the Black-Scholes option model, these warrants have
zero value based on volatility of 0.01%; therefore, no compensation was
recorded.

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.

All shares of Solomon were disposed of in open market
transactions effected through NASD member broker firms. All shares of Hydrogen
were disposed of via distributions to third parties in private transactions.

See attached Schedule A (Solomon) and Schedule B
(Hydrogen) for (b), (c) and (d), above.

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.

In accordance with paragraph 18 of APB 19, Accounting for
Nonmonetary Transactions, fair value was used in accounting for the
distributed asset (Solomon shares). On the date of distribution, January 7,
2004, fair value was the same as cost; therefore, no gain and loss was recorded
on this transaction. Because the Company did not have retained or current
earnings, such distribution was presented as a reduction of 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.

The following revised section 302 certification by each of the
principal executive and principal financial officers will be filed with amended
Form 10KSB for 2004 and Forms 10QSB for the quarters ended March 31, 2005 and
June 30, 2005.

"Certification Required by Rule 13a-14(a) or Rule 15d-14(a) as
Adopted Pursuant to Section 302 of the Sarbanes-Oxley Act of 2002

I, Kevin J. High, certify that:

      1.

      I have reviewed this Quarterly Report on Form 10-QSB of Cytation
      Corporation.;

      2.

      Based on my knowledge, this quarterly report does not contain any
      untrue statement of a material fact or omit to state a material fact
      necessary to make the statements made, in ligh