SecProbe.io

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Mail Stop 0308

January 3, 2005
Savoy Financial Group
6767 West Tropicana Avenue, Suite 207
Las Vegas, Nevada 89103

Re: Expert Systems, Inc.
       Form SB-2/A filed December 22, 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.

Financial Statements
Statement of Operations - page 31

1.	For the restated year ended December 31, 2003, you indicate
that
you have
3, 364,000 weighted average common shares outstanding. Appendix E
of
SFAS 128 defines weighted average number of shares outstanding as
"the number of shares determined by relating (a) the portion of
time
within a reporting period that common shares have been outstanding
to
(b) the total time in that period." Please explain how you
calculated
the 3,364,000 figure. We note that, at the beginning of the
reporting
period, January 1, 2003, you had 5,000,000 shares outstanding and
that you issued another 375,000 shares in December 2003. Please
also
show us how you computed the number of  weighted average shares
for
2002. To the extent necessary, please amend your filing and revise
your financial statements to reflect the correct weighted average
common shares outstanding for all years and interim periods
presented.

					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

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Expert Systems, Inc.
Page 2

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