SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 0308
									October 29, 2004
Savoy Financial Group
6767 West Tropicana Avenue, Suite 207
Las Vegas, Nevada 89103

Re: Expert Systems, Inc.
       Form SB-2/A filed October 14, 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.	The page reference to the "Plan of Distribution" section appears
to be incorrect. Please check for accuracy.

2. 	Also, this section of the prospectus should describe briefly the
methods Winton and Griffin will use in their sales efforts, e.g.,
telephone, personal communications, mail, etc.

Description of Business - page 18

3.	The risk factor section should also include an additional risk
factor, appropriately sub-titled, noting that the registrant is
dependent on a foreign manufacturer for the supply of its only
product, and describing briefly any difficulties which may affect its
business or results of operations if the supply of the product is
interrupted or its quality is compromised as a result of this
arrangement.

Interest of Named Experts and Counsel - page 17

4.	Please explain how Bagel, Josephs & Company, LLC do not meet the
requirements of an "Expert" as defined by Item 509(a) of Regulation
S-B. We may have further comments.

Financial Statements
Audited Financial Statements for the Years Ended December 31, 2003
and 2002
Independent Auditors` Report - page 32
5,	The title of your independent auditors` report, as well as your
accountants` review report on page 41, should state "Report of
Independent Registered Public Accounting Firm", as shown in the
illustrative report examples in the appendix of Auditing Standard No.
1, References in Auditing Reports to the Standards of the Public
Company Accounting Oversight Board. Please have your auditors revise
the headings of both reports. Additionally, the consent in exhibit 23
should read "Consent of Independent Registered Public Accounting
Firm".

Statement of Changes in Stockholders` Equity - page 35
6.	We note your response to comment number 28. We continue to
believe you have not adequately justified using par value of your
common stock as your determination of fair value for common stock
issued to each of your directors. Paragraph 10 of APB Opinion 25
states, in part, that if a quoted market price is unavailable, the
best estimate of the market value of the stock should be used to
measure compensation. We feel that the best estimate of market or
fair value could be a combination of the two separate stock issuances
to unrelated third parties where the price per share was four cents
and your proposed offering price per share for this registered public
offering was five cents.  Alternatively, an effort could be
undertaken to provide a value of the services and derive a per share
fair value under that method. The financial statements are
management`s responsibility. We reiterate that it does not appear
that par value would be a good indication of fair value to assign as
value to the stock issued for services, and therefore ask for further
explanation and/or consideration of your valuation.
Notes to Financial Statements
Note 2 - Summary of Significant Accounting Policies
Development Stage Company - page 37

7.	We note your response to comment  29 of our letter to you dated
September 30, 2004, and still believe your disclosures to be unclear.
Please explain how you "devoted substantially all of your efforts to
business planning and research and development" but did not spend any
money on research and development activities. Please clarify and
revise your disclosures as necessary.

Note 4 - Going Concern
8.	We do not believe you answered the question included in comment
30. Please tell us how you complied with the disclosure
considerations in AU 341.10 of the AICPA professional standards. We
may have further comments.

Part II

Signatures

9.	We note that Mr. Winton has signed the registration statement as
Treasurer. Since the signature requirement is specific and
conjunctive, please re-execute to state specifically which individual
is signing as the company`s chief financial officer and as the chief
accounting officer, respectively, even if it is the same individual
in each case, and even if the specified individual has a different
formal title.

					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 1

</TEXT>
</DOCUMENT>