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September 30, 2005

United States Securities and Exchange Commission
Division of Corporation Finance
c/o Ms. Kristin Lochhead, Mr. Brian Cascio, Mr. Gary Todd
100 E Street, NE
Washington, D.C. 20549

The following letter is DTLL's management response to the Securities and
Exchange Commission information request letter dated August 19, 2005. The format
of the response letter includes each of SEC's requests re-written. Underneath
each of the requests is DTLL's response to the request. We welcome any questions
or comments you may have about our responses.

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

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 and identify as critical. Disclosure that merely
      repeats basic accounting policies will not generally satisfy the
      objectives of the disclosure.

      DTLL RESPONSE:
      Comment noted and included within quarterly procedures.

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.

      DTLL RESPONSE:
      Until March 20, 2003, the Company was principally engaged in manufacturing
      and marketing associated groups of dental related products to dentists,
      dental clinics, hospitals and dental laboratories. On March 20, 2003, the
      Company's shareholders approved the sale of substantially all of its
      assets to DRIA, LLC, based on an asset purchase agreement dated November
      1, 2002. Since all of the operations and business lines were sold, there
      were no significant operations left in 2003, which was disclosed in the
      footnotes and the MD&A. For that reason, management felt that a separation
      of continuous vs discontinued operations is in accordance with SFAS 144
      Paragraph 42 and this presentation was

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      more informative to the reader. Currently, it is clear within the most
      recent 10Q that DTLL is a development stage company and it is anticipated
      that DTLL's business will consist of development and marketing of
      prescription pharmaceutical products.

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.

      DTLL RESPONSE:
      Comment noted and included within quarterly procedures.

Note 3 - Transaction

      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 described in the
            guidance. Your response should fully describe how you applied the
            referenced guidance in your fact pattern.

            DTLL RESPONSE:
            EITF 98-3 Paragraph 6 it states "A business consists of (a) inputs,
            (b) processes applied to those inputs, and (c) resulting outputs
            that are used to generate revenues. For a transferred set of
            activities and assets to be a business, it must contain all of the
            inputs and processes necessary for it to continue to conduct normal
            operations after the transferred set is separated from the
            transferor, which includes the ability to sustain a revenue stream
            by providing its outputs to customers."

            DTLL only obtained intellectual property from this exchange and did
            not include any other inputs, processes and outputs defined within
            paragraph 6. Based on this, DTLL is not considered a business for
            this exchange.

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      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.

            DTTL RESPONSE:

            DTLL issued 12.5 million shares of its stock in exchange for
            Gelstat's intellectual property. SAB Topic 5-G paragraph 4 it states
            "The staff will not always require that predecessor cost be used to
            value nonmonetary assets received from an enterprise's promoters or
            shareholders." DTLL believes there is value in the issuance of 94%
            of its outstanding stock. The offset to this value (debit side of
            the transaction), based on Topic 5-G, can not be booked as an asset
            as no value is attributable to the intellectual property, so the
            only logical alternative is to book the offset to Research and
            Development expense. Similarly, if DTLL would have issued cash for
            the intellectual property it would have to offset the cash value
            (debit side of the transaction) to a different account. Taking this
            approach, the net effect of the value of the intellectual property
            is zero as it is expensed immediately.

      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.

            DTLL RESPONSE:
            DTLL did not acquire a business (see item a above).

      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(s) to Regulation S-B. Revise or
            advise.

            DTLL RESPONSE:
            DTLL did not acquire a business (see item a above).

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Liquidity and Capital Resources

3.    In the 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.

      DTLL RESPONSE:
      Comment noted and included within quarterly procedures.

      In connection with these responses to your requests, DTLL acknowledges
that:

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

      o     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

      o     The company may not assert staff comments as a defense in any
            proceeding initiated by the Commission or any person using the
            federal securities laws of the United States.

Sincerely,

By  /s/ Stephen C. Roberts
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 Name:  Stephen C. Roberts
 Title: Chairman and Chief Executive Officer

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