SecProbe.io

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Mail Stop 6010
      August 19, 2005

VIA U.S. MAIL AND FACSIMILE (952) 881-4472

Mr. Stephen Roberts
Chief Financial Officer
DTLL, Inc.
1650 West 82nd Street
Suite 1010
Bloomington, Minnesota 55431

      Re:	DTLL, Inc.
		Form 10-KSB for the year ended December 31, 2004
      Filed March 31, 2005
		File No. 000-30608

Dear Mr. Roberts:

      We have reviewed your filing 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 document 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 filing.
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 transition period ended December 31, 2004

Item 6.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations
1. Please expand future filings to provide critical accounting
policy
disclosure.  Refer to FR-60 and FR-72 for guidance. Please note
that
critical accounting policy disclosure should provide insight about
the nature and extent complex judgments and estimates that
underlie
the accounting policies you identify as critical.  Disclosure that
merely repeats basic accounting policies will not generally
satisfy
the objectives of the disclosure.

Financial Statements

2. Tell us why the statement of operations for fiscal 2003 does
not
present the operations of the disposed dental business as
discontinued operations.  Refer to SFAS 144.

Forms 10-Q for the periods ended March 31, 2005 and June 30, 2005
Financial Statements

3. Expand future filings to clarify whether your financial
statements
are consolidated with those prepared for Gelstat Corporation.
Note 3 - Transaction
4. We note that you issued 12.5 million shares of common stock to
a
subsidiary of GelStat in exchange for an exclusive worldwide
license
of all rights to pharmaceutical technology.  As a result of this
transaction, GelStat obtained 94% of your outstanding shares and
control of management.  In addition, you intend to change your
name
to GS Pharma.   You have recorded an expense for in process
research
and development for $409,377, which is the assigned value of the
exclusive license.   We have the following comments as it relates
to
this transaction:
a) With respect to the acquired activities, supplementally
describe
your consideration of EITF 98-3.  That is, tell us whether the
acquired operations constitute a business as describe in the
guidance.  Your response should fully describe how you applied the
referenced guidance in your fact pattern.

b) If you did not acquire a business based on the guidance from
EITF
98-3, tell us why the accounting guidance from SAB Topic 5-G is
not
applicable.  That is, since a Gelstat subsidiary became your
controlling shareholder in the transaction and continues to
control
the technology, explain why predecessor basis accounting is not
required. Under predecessor basis accounting it appears that no
value
would be attributed to the technology since we presume any
historical
costs were expensed as incurred. Please be detailed and specific.

c) If the acquired operations are a business based on your
analysis
of EITF 98-3, tell us why reverse merger accounting is not
applicable.  That is, since a subsidiary of Gelstat acquired
control
in the transaction, then that subsidiary appears to be the
accounting
acquirer.  Your written response should describe how you applied
the
guidance from paragraphs 15-19 of SFAS 141.

d) As a matter related to c) above, under reverse merger
accounting
the historical financial statements of the accounting acquirer
become
the financial statements of the registrant for all applicable
periods
prior to the transaction; and, the transaction is presented as the
acquisition of the issuer company by the accounting acquirer.  If
acquired operations are, in fact, a business as defined in GAAP,
then
it appears that you should amend the Forms 10-QSB for fiscal 2005
to
provide historical financial statements for the accounting
acquirer
for the periods specified by Item 310(b) to Regulation S-B. That
is,
comparative prior periods should reflect the financial position,
results of operations and cash flows of the accounting acquirer.
As
well, you should provide a Form 8-K presenting audited historical
financial statements for the accounting acquirer for the periods
specified in Item 310(a) to Regulation S-B.  Revise or advise.

Liquidity and Capital Resources
5. In future filings please expand your discussion of liquidity
and
capital resources to more specifically discuss your plans to
generate
sufficient liquidity, financing needs and expected sources of this
financing. We note that you have approximately $200,000 of cash on
hand at March 31, 2005 and estimate that you will need $5 million
to
complete Phase II clinical trials.  The discussion should also
contain appropriate and prominent disclosure of your financial
difficulties and viable plans to overcome these difficulties and
resolve the doubts about your continued existence.  Refer to FRC
607.02.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comments and provides any requested information.
Detailed cover letters greatly facilitate our review.  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 filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed 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 filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; 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 filing or in
response to our comments on your filing.

	You may contact Kristin Lochhead at (202) 551-3664 or me at
(202) 551-3605 if you have questions.  In this regard, please do
not
hesitate to contact Brian Cascio, Accounting Branch Chief, at
(202)
551-3676 with any other questions.

      Sincerely,

      Gary Todd
      Reviewing Accountant

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Mr. Roberts
DTLL, Inc.
August 19, 2005
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