SecProbe.io

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<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
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ANDREW I. TELSEY, P.C. - Attorney at Law
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    12835 E. Arapahoe Road, Tower One, Penthouse #803, Englewood, Colorado 80112
  Telephone: (303) 768-9221 / Facsimile (303) 768-9224 / E-mail: aitelsey@cs.com

November 1, 2005

VIA EDGAR

Mr. Patrick Gilmore, Staff Accountant
US Securities and Exchange Commission
450 Fifth Street, N. W.
Washington, D.C.  20549

Re:     Alpha Spacecom, Inc.;
        Form 8-K, Item 4.01 Filed May 13, 2005, June 14, 2005 and August 4, 2005
        SEC File No. 000-13628
        Response to August 9, 2005 Letter

Dear Mr. Gilmore:

On behalf of the above  referenced  registrant (the  "Company"),  this letter is
intended  to provide a  response  to the  staff's  letter  dated  August 9, 2005
concerning the above referenced report.  Relevant thereto,  please note that the
Company filed another  amendment to said report with the  Commission on or about
October 28,  2005.  In regard to the same and in  response to the staff's  above
referenced  letter,  please be advised as follows.  Each response numbered below
corresponds to the staff's applicable comment in its aforesaid letter:

     1. The  letter  from  DeJoya  &  Company,  included  as an  exhibit  to the
Company's  Form 8-K,  contained a list of five alleged  "disagreements"  between
that firm and the Company.  However,  a review of the contents  included in said
letter determines that, in reality,  only the initial two items included in said
letter were, in fact,  disagreements.  On behalf of the Company, it is submitted
that  Items  III,  IV and V  included  in  this  letter  were  not  and  are not
"disagreements on any matter of accounting principles or practices," but rather,
events which,  according to De Joya & Co.,  occurred  during the audit  process.
Subsequent  to the  issuance  of this  letter  and  filing  of the  report,  the
Company's  President and CEO withdrew his claim that he had incurred  additional
expenses. Therefore, the only outstanding disagreement related to Item II of the
De Joya letter. The amended Form 8-K addresses this disagreement and attempts to
explain what the Company believes to be the reason for such disagreement.

     2. The most recent amendment to the Company's Form 8-K includes a currently
dated  letter  from De Joya & Company  relating  to  disagreements  between  the
Company and De Joya.

     3. The  Company  believes  that its most recent  amendment  to its Form 8-K
includes all disclosure required under Regulation SB. Specifically,  The amended
report  addresses  all of the issues raised in Item  304(a)(1)(i)  through (iv).
Further,  subparagraph  (B) is not  applicable,  as De Joya did not  advise  the
Company  of any  matter  addressed  in  subsections  (1)  through  (3)  therein.
Subsection (C) is identified in the amended report.  Relevant to Subsection (D),
obviously, discussions between the Company's Board of

<PAGE>
Mr. Patrick Gilmore
US Securities and Exchange Commission
November 1, 2005
Page 2

Directors and De Joya took place,  but due to the nature of the  relationship as
we discussed in our phone conversation of this date, these discussions  resulted
in no resolution of the existing dispute. Finally, relevant to subsection (E), a
new sentence has been added to the amended report relevant to this issue.

In  addition,  relevant  to  Section  (a) (2) of Item 304,  the  amended  report
discloses  the Company's  new  accountant  and confirms that the Company did not
consult  with the  Company's  new  accountant  on  those  matters  described  in
subsections  (i) and (ii) of said  subsection.  The Company also  complied  with
Subsection (3), as evidenced by the De Joya letter attached as an exhibit to the
amended  report.  The  Company  also  believes  that it has  complied  with  the
provisions  included  in  subparagraph  (b) as the  same is  applicable  to this
situation.

Finally, please be advised that management of the Company has provided this firm
with written authorization, authorizing the undersigned to advise the Commission
that management of the Company acknowledges the following:

     1. That it is  responsible  for the adequacy and accuracy of the disclosure
in its  filings,  including  but not  limited to the amended  Form 8-K  relevant
herein;

     2. That 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

     3. That it 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 the event you wish to discuss any of the responses  included  herein,  or any
other matter  concerning  the Company,  please  contact the  undersigned  at the
address and phone number listed on the preceding page.

Thank you for your cooperation in this matter.

Yours truly,

ANDREW I. TELSEY, P.C.

s/Andrew I. Telsey

Andrew I. Telsey
For the Firm

cc:   Client (via fax only)
      R. Chadwick (via fax only)

AIT/ddk

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