SecProbe.io

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<TYPE>CORRESP
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<FILENAME>filename1.txt
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ANDREW I. TELSEY, P.C.  Attorney at Law
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   12935 E. Arapahoe Road, Tower One, Penthouse #803, Englewood, Colorado  80112
  Telephone:  303/768-9221 - Facsimile:  303/768-9224 - e-mail:  aitelsey@cs.com

January 13, 2005

VIA EDGAR

Larry Greene, Esq.
Senior Counsel
US Securities and Exchange Commission
Washington, D.C.

Re:      Exus Global, Inc.
         SEC File No.  0-18049
         Response to Comments on Preliminary Information Statement

Dear Mr. Greene:

Pursuant  to  our  telephone  conversation  of  Wednesday,   January  12,  2005,
concerning the above referenced  matter,  this letter is intended to memorialize
the  responses of Exus Global,  Inc.  (the  "Company"),  to your comments to the
above referenced Information Statement (the "Information Statement").  Following
is a description of your three comments and our responses thereto:

1. You requested  clarification  of the disclosure on page 3 of the  Information
Statement  relating to the fact that the Reverse  Stock Split (as defined in the
Information  Statement),  would  have no  impact  on the  Company's  outstanding
Convertible  Debentures  (the  "Debentures")  and Series B Preferred  Stock (the
"Preferred Stock"), each of which contain a conversion feature, convertible into
shares of the Company's  common stock.  In response  thereto,  we did advise you
that the  conversion  price of the  Debentures  is based  upon the then  current
market price of the Company's  common  stock.  It is the position of the Company
that the  Reverse  Stock  Split  will have no impact  on any  conversion  by the
Debenture holders because the percentage of shares of the Company's common stock
to be obtained by such holders upon conversion will not be affected. For example
only, if the current price of the Company's  common stock  immediately  prior to
the Reverse Stock Split is $.10 per share, the price following the 1:200 Reverse
Stock Split would be $20.00. A holder of a $100 Debenture who elected to convert
prior to the Reverse  Stock Split would  receive  1,000 shares of common  stock,
representing  a market  value of $100.  If the same  holder  elected  to convert
immediately  following the Reverse Stock Split, he would receive 5 shares of the
Company's common stock having a market value of $100 under this scenario.

Concerning the Preferred  Stock,  the shareholders of the Company had previously
adopted an amendment to the Company's  Articles of Incorporation  which provides
that any reverse  stock  split  undertaken  by the Company  would not affect the
conversion  feature included in the Certificate of Designations  relating to the
Preferred Stock. As such, in our aforesaid  telephone  conversation,  you agreed
with the analysis  relating to both the  Debentures  and Preferred  Stock and no
change to the

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Larry Greene, Esq.
U.S. Securities and Exchange Commission
January 13, 2005
Page 2

Information Statement relating to these matters is required.

2. Your second comment  related to the  disclosure on page 4 of the  Information
Statement,  wherein the Company discussed the possible  anti-takeover  effect of
the Reverse Stock Split.  After  discussing the same, we agreed that the Company
would include a statement in its  definitive  Information  Statement to be filed
with the  Commission  to the effect  that such  anti-takeover  provisions  could
negatively  impact the Company's  shareholders by depriving them of any benefits
of such action if the attempted hostile takeover  opportunity provided a premium
to the then current market price of the Company's common stock.

3. Your final comment to the Information  Statement related to the disclosure on
page 6,  wherein  the  Company  advised  that it was unable to  provide  the new
trading  symbol for the  Company's  common stock upon  adoption of the Company's
name  change.  After  discussion,  we did agree  that the  Company's  definitive
Information  Statement  to be filed with the  Commission  will  include  the new
trading symbol for the Company's common stock.

At the  conclusion of our telephone  conversation,  you advised the  undersigned
that the staff has no further comments to the Information Statement.

Further,  in connection with the above responses,  the Company  acknowledges the
following:

a. The Company is responsible for the adequacy and accuracy of the disclosure in
its Information Statement;

b. Staff  comments or changes to disclosure in response to staff comments in the
Information Statement reviewed by the staff do not foreclose the Commission from
taking any action with respect to the filing; and

c. The Company  may not assert  staff  comments  to a defense in any  proceeding
initiated by the Commission or any person under the federal  securities  laws of
the United States.

Thank you for your  cooperation in this matter.  In the event you have any other
concerns regarding this matter, please contact the undersigned.

Yours truly,

ANDREW I. TELSEY, P.C.

s/Andrew I. Telsey

Andrew I. Telsey
For the Firm

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