SecProbe.io

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                               MERITZ & MUENZ LLP

                                COUNSELORS AT LAW

                                2021 O Street, NW
                              Washington, DC 20036

                                   ___________

                            Telephone: (202) 787-1964
                            Facsimile: (202) 787-3909
                           E-mail: Lmuenz@comcast.net

                                December 3, 2004

Mr. Reginald Norris
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

Re:  Accessity Corp. Preliminary Proxy Response to SEC Comments

Dear Mr. Norris:

In response to our discussion via telephone, on behalf of Accessity Corp.
("Accessity"), I hereby provide you with the following response:

Proposal 3 Approval of Subsidiary Transfer
------------------------------------------

1.   SEC Comment: "In the front and the body of the Proxy, state the business
     reasons for the subsidiary transfer."

     Response: Added language to state the business purpose was to have Mr.
     Siegel relinquish cash payments that otherwise would be due him under his
     respective employment agreements with Accessity as a result of the
     consummation of the Share Exchange. The applicable revisions appear on
     pages 7, 95 and 140 as attached.

2.   SEC Comment: "State any additional compensation that will be paid to Mr.
     Siegel and/or Mr. Kart related to this transfer."

     Response: Added language to state that the Subsidiary Transfer, in addition
     to other stated compensation was in ". . . in full consideration for the
     agreement of each of Messrs. Siegel and Kart to relinquish cash payments
     that otherwise would be due to each of them under their respective
     employment agreements with Accessity as a result of the consummation of the
     Share Exchange." The applicable revisions appear on pages 2, 7 and 140 as
     attached.

3.   SEC Comment: "Clarify that the Board of Directors approved this proposal
     Mr. Reginald Norris
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Securities and Exchange Commission
December 3, 2004
Page 2

     without Mr. Siegel's influence and the support of disinterested directors."

     Response: Added language to state that: ". . .the board of directors,
     without any influence from Barry Siegel, by unanimous vote of a majority of
     the disinterested directors, has determined that the Subsidiary Transfer
     and the Subsidiary Sale are in the best interests of the holders of
     Accessity's common stock." The applicable revisions appear on pages 3, 140
     and 143 as attached.

4.   SEC Comment: "Summarize the BearingPoint opinion."

     Response: Please see pages 140 through 142 as attached.

Proposal 4 Approval of Subsidiary Sale
--------------------------------------

1.   SEC Comment: "In the front of the Proxy, specify the sale price of $5,000."

     Response: Added the purchase price of $5,000. The applicable revisions
     appear on pages 1, 2 and 8 as attached.

2.   SEC Comment: "Explain the business reasons for the sale to Mr. Siegel for
     the price of $5,000."

     Response: Added language to state: "Rather than discontinuing the
     operations of Sentaur upon the consummation of the Share Exchange, the
     disinterested members of Accessity's board of directors unanimously decided
     to entertain offers from interested parties willing to pay Accessity a
     nominal purchase price for Sentaur." The applicable revision appears on
     page 143 as attached.

I hope that you find our response to your comments acceptable. It is my
understanding that you will contact me to advise me via telephone when we can
file the Definitive Proxy.

Please be advised that we will be inserting financial statements for the nine
months ended September 30, 2004 in place of the financial statements for the six
months ended June 30, 2004.

Mr. Reginald Norris

Thank you in advance for your prompt reply to this letter.

                                        Respectfully yours,

                                        Lawrence A. Muenz

Attachment

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                                                                          PAGE 1

                                 ACCESSITY CORP.
                          12514 WEST ATLANTIC BOULEVARD
                          CORAL SPRINGS, FLORIDA 33071

                              --------------------

                    NOTICE OF ANNUAL MEETING OF SHAREHOLDERS
                         TO BE HELD ON DECEMBER 28, 2004

                              --------------------

      NOTICE IS HEREBY GIVEN that the 2004 annual meeting of the shareholders of
Accessity Corp. ("Accessity") is to be held on December 28, 2004, at the Coral
Springs Marriott Hotel, Golf Club and Convention Center, 11775 Heron Bay
Boulevard, Coral Springs, Florida 33076 at 10:00 a.m., local time, for the
following purposes:

      1.    To elect Bruce S. Udell as a Class III director of Accessity.

      2.    To consider and approve the issuance of shares of common stock of
            Accessity to the shareholders of Pacific Ethanol, Inc., a California
            corporation ("PEI") and the limited liability company members of
            Kinergy Marketing, LLC ("Kinergy") and ReEnergy, LLC ("ReEnergy"),
            in exchange for their ownership interests in such companies, and the
            issuance of warrants to acquire shares of common stock of Accessity
            to holders of issued and outstanding options and warrants to acquire
            shares of common stock of PEI, pursuant to the Share Exchange
            Agreement dated as of May 14, 2004, as amended on July 30, 2004 and
            as of October 1, 2004 (as amended, the "Share Exchange Agreement"),
            and the consummation of the transactions contemplated thereby
            (collectively the "Share Exchange"). Upon consummation of the Share
            Exchange, each of PEI, Kinergy and ReEnergy will become a
            wholly-owned subsidiary of Accessity. A copy of the Share Exchange
            Agreement is attached as APPENDIX A to the proxy statement
            accompanying this notice.

      3.    To consider and approve the transfer of DriverShield CRM Corp., a
            wholly-owned subsidiary of Accessity, to Barry Siegel, the current
            Chairman of the Board, President and Chief Executive Officer of
            Accessity, if the Share Exchange is approved by the shareholders.

      4.    To consider and approve the sale of Sentaur Corp., a wholly-owned
            subsidiary of Accessity, to Barry Siegel, FOR THE SUM OF $5,000, if
            the Share Exchange is approved by the shareholders.

      5.    To approve a new 2004 Stock Option Plan of Accessity, if the Share
            Exchange is approved by the shareholders.

      6.    To consider and approve the reincorporation of Accessity in the
            State of Delaware under the name "Pacific Ethanol, Inc." to occur
            immediately prior to the consummation of the Share Exchange, if the
            Share Exchange is approved by the shareholders.

      7.    To consider and approve an amendment to the articles of
            incorporation of Accessity to change the name of Accessity to
            "Pacific Ethanol, Inc." effective immediately prior to the
            consummation of the Share Exchange, if the Share Exchange is
            approved by the shareholder and the reincorporation of Accessity in
            the State of Delaware does not occur.

      8.    To transact such other business as may properly come before this
            annual meeting or any adjournment or postponement thereof.

      The foregoing proposals are more fully described in the accompanying proxy
      statement.
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                                                                          PAGE 2

      an aggregate of 1,188,487 shares of Accessity common stock at exercise
prices ranging from $0.0001 per share to $2.00 per share in exchange for
cancellation of outstanding options and warrants.

      The Board of Directors of Accessity has also approved, subject to the
approval of the Share Exchange by Accessity shareholders:

      o     the transfer of DriverShield CRM Corp. ("DriverShield"), a
            wholly-owned subsidiary of Accessity, to Barry Siegel, the current
            Chairman of the Board, President and Chief Executive Officer of
            Accessity, the issuance of up to 400,000 shares of Accessity common
            stock to Barry Siegel and 200,000 shares of Accessity common stock
            to Philip Kart, Accessity's current Chief Financial Officer AND the
            execution of a consulting and noncompetition agreement between
            Accessity and each of Barry Siegel and Philip Kart (COLLECTIVELY,
            THE "SUBSIDIARY TRANSFER"), IN FULL CONSIDERATION FOR the agreement
            of each of Messrs. Siegel and Kart to relinquish cash payments that
            otherwise would be due to each of them under their respective
            employment agreements with Accessity as a result of the consummation
            of the Share Exchange;

      o     the sale of Sentaur Corp. ("Sentaur"), a wholly-owned subsidiary of
            Accessity, to Barry Siegel FOR THE SUM OF $5,000 (the "Subsidiary
            Sale");

      o     the 2004 Stock Option Plan of Accessity (the "2004 Plan");

      o     the reincorporation of Accessity in the State of Delaware under the
            name "Pacific Ethanol, Inc." to occur immediately prior to the
            consummation of the Share Exchange (the "Delaware Reincorporation");
            and

      o     an amendment to the articles of incorporation of Accessity to change
            the name of Accessity to "Pacific Ethanol, Inc." effective
            immediately prior to the consummation of the Share Exchange, if the
            Share Exchange is approved by the shareholders and the Delaware
            Reincorporation does not occur (the "Corporate Name Change").

      The Delaware Reincorporation will be effected through a merger of
Accessity with and into a wholly-owned Delaware subsidiary of Accessity named
Pacific Ethanol, Inc., to be formed for the purpose of effecting the
reincorporation (the "Delaware Reincorporation Subsidiary"). In lieu of
receiving common stock of the Delaware Reincorporation Subsidiary, Accessity
shareholders will have dissenters' rights. Accessity shareholders who properly
demand these rights will receive cash for the fair value of the Accessity common
stock that they held prior to the merger. The fair value would be determined by
a court or by agreement between Accessity and its shareholders who exercise
their dissenters' rights. If the proposal to reincorporate Accessity in the
State of Delaware is approved by the Accessity shareholders, but Accessity
receives demands for exercise of dissenters' rights that exceed 1% of the
outstanding shares of Accessity common stock, Accessity's board of directors may
elect not to proceed with the reincorporation. If the board of directors elects
not to proceed with the reincorporation or if the proposal is not approved by
Accessity's shareholders, Accessity will remain a New York corporation, provided
the Corporate Name Change is approved by the shareholders, Accessity and will
change its name to Pacific Ethanol, Inc. If, however, the Delaware
Reincorporation is approved, the Delaware Reincorporation Subsidiary will
succeed to the rights, properties and assets and assume the liabilities of
Accessity, and its financial statements will be substantially identical to
Accessity, the only difference being those appropriate to reflect Accessity's
new corporate identity, the Share Exchange and the Subsidiary Transfer. This new
company (i.e., Accessity Corp., a New York corporation, renamed Pacific Ethanol,
Inc. or the Delaware Reincorporation Subsidiary named Pacific Ethanol, Inc.),
which combines the operations of the Acquired Companies, is referred to in this
proxy statement as the "Combined Company." Accessity shareholders will vote on
the matters described in this
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                                                                          PAGE 3

      Accessity shareholders will vote on the matters described in this proxy
statement at the annual meeting of shareholders on the date set forth above. At
the annual meeting, you will be asked:

      o     to elect Bruce S. Udell as a Class III director of Accessity
            (Proposal 1);

      o     to approve the issuance of shares of Accessity common stock and
            options and warrants in the Share Exchange pursuant to the Share
            Exchange Agreement and the consummation of the transactions
            contemplated thereby (Proposal 2);

      o     to approve the Subsidiary Transfer (Proposal 3), if the Share
            Exchange is approved by the shareholders;

      o     to approve the Subsidiary Sale (Proposal 4), if the Share Exchange
            is approved by the shareholders;

      o     to approve the 2004 Plan (Proposal 5), if the Share Exchange is
            approved by the shareholders;

      o     to approve the Delaware Reincorporation (Proposal 6), if the Share
            Exchange is approved by the shareholders; and

      o     to approve the Corporate Name Change (Proposal 7), if the Share
            Exchange is approved by the shareholders and the Delaware
            Reincorporation does not occur.

Neither the Share Exchange nor the other matters described in this proxy
statement (other than the election of a Class III director) can be completed
unless the shareholders of Accessity approve the Share Exchange and the other
matters described in this proxy statement (other than the election of a Class
III director).

RECOMMENDATION OF ACCESSITY'S BOARD OF DIRECTORS

      The board of directors of Accessity, by unanimous vote, has determined
that the Share Exchange is in the best interests of the holders of Accessity's
common stock. In addition, the board of directors, WITHOUT ANY INFLUENCE FROM
BARRY SIEGEL, by unanimous vote of the disinterested directors, has determined
that the Subsidiary Transfer and the Subsidiary Sale are in the best interests
of the holders of Accessity's common stock. The decisions of the board of
directors of Accessity to enter into the Subsidiary Transfer are based upon its
evaluation of a number of factors, including, among others, the written opinion
dated October 9, 2004, and confirmed in writing as of the date of this proxy
statement, of BearingPoint, Inc. ("BearingPoint") that, based upon and subject
to the matters set forth in the written opinion, as of such dates, the
Subsidiary Transfer is fair from a financial point of view to Accessity and the
shareholders of Accessity. See "Proposal 3--Approval of the Subsidiary
Transfer--Fairness Opinion." In addition, the board of directors of Accessity,
by unanimous vote, has determined that the approval of 1995 Plan amendment, the
2004 Plan, and the Delaware Reincorporation is in the best interests of the
shareholders of Accessity.

HOW TO VOTE

      Shares held directly in your name as the "Shareholder of Record" may be
voted in person at the annual meeting. If you choose to do so, please bring the
enclosed proxy card or proof of identification. Even if you currently plan to
attend the annual meeting, we recommend that you also submit your proxy card as
described below so that your vote will be counted if you later decide not to
attend the annual meeting. Shares held through a broker or other nominee may be
voted in person by you only if you obtain a signed legal proxy from the record
holder giving you the right to vote the shares.
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                                                                   PAGES 7 AND 8