SecProbe.io

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Savoy Financial Group, Inc.
September 24, 2004
6767 W. Tropicana Avenue, Suite 207
Las Vegas, Nevada 89103

Re: Expert Systems, Inc.
       Form SB-2 filed September 2, 2004
       File No.: 333-118799

To Whom It May Concern:

	We have the following comments on the above captioned filing.
Where indicated , we think you should revise your document in
response to these comments. If you disagree, we will consider your
explanation of why our comment is inapplicable or a revision is
unnecessary. Please be as detailed as possible in your explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your disclosure.
After reviewing this information, we may raise additional comments.

Prospectus
Cover Page

1.	Please clarify, in the second paragraph, whether the registrant
is also reserving discretion to terminate the offering in less than
90 days even if more than the minimum amount of proceeds but less
than the maximum has been received.

2.	 State also whether the registrant is reserving the right to
extend the offering period beyond the original 90 days. In that case,
state the maximum outside date beyond which the offering will not be
extended.

3.	State briefly, with a cross-reference to more complete
information elsewhere, which persons at the company will make the
selling effort and what methods they will use.

4.	The statement that Expert Systems does not plan to use this
prospectus before the effective date creates an implication that this
plan may change, and should be deleted. Since use of the prospectus
prior to the effective date is expressly prohibited in any case, the
purpose of the statement is unclear.

5.	Please delete the last sentence of the third paragraph,
referring to the absence of exchange or Nasdaq listings.

Summary Information and Risk Factors - pages 5-11

6. 	Your summary financial information presented on page 6 includes
operations data for the three months ended June 30, 2004 and 2003.
Please explain to us why the amounts for the three months are the
same as those for the six months ended June 30, 2004 and 2003, per
your statement of operations on page 40. If this is a result of not
having any activity during the first three months of each year,
please explain. If it is a typographical error, please revise.

7.	Please clarify that the company`s auditors have included in
their certificate on the company`s financial statements a
qualification for its ability to continue as a going concern.

Risk Factors - pages 7-11

8.	Please delete the last sentence of the second paragraph, which
mitigates the risk discussed.

9.	In the third risk factor discussion, clarify, both in the
headnote and the text, that the auditors have qualified their
certificate to express their doubt about the company`s status as a
going concern.

10.	Please revise the fourth risk factor discussion, both in the
headnote and in the text, to eliminate references to the company`s
operating results, and to clarify rather that the company has had no
operations to date, and may not succeed in ever having any.

11.	Further revise this discussion to eliminate the reference to
securities analysts, which may be speculative, and the reference to
factors which may affect their analysis, which is also presumptive.

12.	Provide an additional, separate risk factor which discusses the
likelihood of severely limited trading in the company`s stock, or the
possibility that no market at all may develop.

13.	An additional risk factor should discuss the apparent likelihood
that the stock will not be listed on any exchange or on NASDAQ.
Discuss the effects on trading of the absence of such listings. We
have noted the later discussion of "penny stock" regulation.

14.	Again, at the last paragraph of the risk factor discussion of
seasonality, delete the reference to public market analysts, which is
speculative.

15.	Please expand the risk factor discussion of competitive
pressures to identify at least the broad categories of your
competitors, and to clarify whether competitors offer the Swing Plane
product or other versions of the same product.

16.	Include at your risk factor discussion of dilution a cross-
reference to the table or text discussion illustrating various levels
of dilution on different assumptions.

17.	Expand the sub-heading "The stock of ESI is a speculative
investment that may result in losses to investors" to indicate
specifically that there can be no assurance that a trading market
will develop.

Use of Proceeds - page 11

18.	We note that at Part II expenses of the offering are estimated
at approximately $8,000. Please reconcile.

Legal Proceedings - page 14

19.	Please state also in this section whether there are any pending
legal proceedings
against the company.

Description of Business - page 18

20.	We note the statement later in the prospectus that the Plane
Stick is currently being assembled in China. Please advise, to the
extent known to the registrant, of the current status of this
assembly, and the source of the registrant`s information.

21. 	Please also advise whether the registrant knows when Plane Stick
would be able to commence deliveries of the product to it. If the
company can reasonably anticipate difficulties in production or
supply, or delays in delivery, which could affect its operations,
please explain.

Management`s Discussion and Analysis - page 21

22.	Please disclose whether you have any off balance sheet
arrangements. Refer to Item 303(c) of Regulation S-B.

Plan of Operation

23.	Clarify, if true, that the company has no obligation to acquire
any minimum quantities of the Swing Plane, whether in a particular
time period or otherwise, from its licensor.

Financial Statements

Audited Financial Statements for the Years Ended December 31, 2003
and 2002

Independent Auditors` Report, page 28
24.	Your independent auditors` reissued report dated January 22,
2004, included in this registration statement, does not appear to
meet the requirements of Auditing Standard No. 1, References in
Auditing Reports to the Standards of the Public Company Accounting
Oversight Board.  Please refer to the Commission`s Release Nos. 33-
8422; 34-49708; FR-73 dated May 14, 2004 available at www.sec.gov.

Statement of Operations, page 31
25.	SFAS 128 requires the disclosure of basic and diluted earnings
per share on the face of the statement of operations. Please disclose
the required information, as applicable, listed in paragraphs 36
through 41 of that Statement. Finally, ensure that you update your
summary financial information and your statement of operations for
the six months ended June 30, 2004 and 2003 with earnings per share
information.

Statement of Changes in Stockholders` Equity (Deficit), page 32
26.	It appears that the $(6,594) deficit for the year ended December
31, 2003 should be a positive number, which would also agree with
your balance sheet. Please remove the brackets if necessary.
Additionally, please revise the heading of Note 3 to read
Stockholders` Equity rather than Stockholders` Deficit.
27.	Please revise the language of the heading in your statement to
reflect all periods presented. The heading should include both the
period April 16, 2002 through December 31, 2002 and the year ended
December 31, 2003. In addition, please correct your index to the
financial statements on page 28 to correspond to the two separate
periods for your statement of changes in stockholders equity.
28.	It appears you used the par value of your common stock as your
determination of fair value for common stock issued to each of your
directors. We noted that you had two separate stock issuances to
unrelated third parties, and in each of those issuances the price per
share was four cents. Furthermore, we note you are proposing an
offering price of five cents per share for this registered public
offering. It does not appear that par value would be a good fair
value method to assign value to the stock issued for services.
Please note that such value should reflect the fair value of the
common stock or the fair value of services rendered, whichever is
more readily determinable. Please provide us with the objective
evidence that you evaluated that supports your determination.

Notes to Financial Statements

Note 2 - Summary of Significant Accounting Policies

Development Stage Company - page 34

29.	We note on page 34, as well as on page 43, your disclosure that
the "Company has devoted substantially all of its efforts to business
planning, research and development." However, on page 20 in your
Description of Business section you state, "We do not conduct any
research or development activities."  Please clarify and revise your
disclosures as necessary.

Note 4 - Going Concern, page 35
30.	Please tell us what consideration you gave to the disclosure
suggestions of AU 341.10 of the AICPA Professional Standards, given
your auditor`s conclusion that there is substantial doubt about your
ability to continue as a going concern for a reasonable period of
time. We may have further comments.

Reviewed Financial Statements for the Periods Ended June 30, 2004 and
2003

Accountants` Review Report - page 38
31.	Your accountants` review report dated July 20, 2004, which is
included in this registration statement, does not appear to meet the
requirements of Auditing Standard No. 1, References in Auditing
Reports to the Standards of the Public Company Accounting Oversight
Board. Please refer to the Commission`s Release Nos. 33-8422; 34-
49708; FR-73 dated May 14, 2004 available at www.sec.gov.

Reviewed Statements of Operations - page 40

32.	Please revise the period headings to read 2004 and 2003 instead
of 2003 and 2002.

Reviewed Statement of Changes in Stockholders` Equity (Deficit) -
page 41
33.	It appears that the $(6,594) deficit for the year ended December
31, 2003 should be a positive number, which would also agree to your
balance sheet.  Please remove the brackets if necessary.
Additionally, please revise the heading of note 3 to read
Stockholders` Equity as opposed to Stockholders` Deficit.
Part II

Recent Sales of Unregistered Securities

34.	In each case where securities were issued for services rendered,
give a brief description of the nature of the services rendered.

Exhibits, page 47
Exhibit 23.2 (b) Consent of Independent Auditor
35.	It appears a consent letter of a different independent auditor
for an unrelated registration statement was included in your filing.
Please amend your filing to include the appropriate consent.

Signatures

36. 	The registration statement must also be signed by the company`s
controller or principal accounting officer and by the company`s
principal financial officer.

General

37.	Notwithstanding our comments, in the event the company requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of the request,
acknowledging that:

* Should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, this does not foreclose the
Commission from taking any action with respect to the filing;
* The action of the Commission or the staff, pursuant to delegated
authority, in declaring the filing effective, does not relieve the
company from its full responsibility for the accuracy and adequacy of
the disclosure in the filing; and
* The company may not assert this action as 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
Corporate Finance in connection with our review of your filing.

	We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of the
fact that those requesting acceleration are aware of their respective
responsibilities under the Securities Act of 1933 and the Securities
Exchange Act of 1934 as they relate to the proposed public offering
of the securities specified in the above captioned registration
statement. We will act upon such request and pursuant to delegated
authority grant acceleration of the effective date.

					General

	Please amend your filing in response to these comments. Provide
a cover letter keying your responses to the comments, and supply any
requested supplemental information. Please also supply supplementally
three copies of the amendment marked to show changes. We may have
further comments after reviewing you revised materials and your
responses.

	Please direct questions on accounting matters to David
DiGiacomo, at (202) 942-
5493, or to James Allegretto, Senior Assistant Chief Accountant, at
(202) 942-1885. Direct other questions to Albert Yarashus, at (202)
942-1899, or to me, at (202) 942-1900.

								Sincerely,

								H. Christopher Owings
						                        Assistant
Director

Expert Systems, Inc.
Page  7

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