SecProbe.io

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<TYPE>LETTER
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<FILENAME>filename1.txt
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Mail Stop 4561
									November 29, 2005

Mr. F. Dale Markham
Chief Executive Officer
REIT Americas, Inc.
2960 N. Swan Road, Suite 300
Tucson, AZ 85712

      Re:	REIT Americas, Inc.
		Form 10-KSB for Fiscal Year Ended December 31, 2004
		Form 10-QSB for Fiscal Quarter Ended March 31, 2005
		Form 10-QSB for Fiscal Quarter Ended June 30, 20005
		File No. 33-11863

Dear Mr. Markham:

      We have reviewed your response letter dated November 5, 2005
and have the following additional comments.  As previously stated,
these comments require amendment to the referenced filings
previously
filed with the Commission.  In some of our comments, we ask you to
provide us with information so we may better understand your
disclosure.  After reviewing this information, we may raise
additional comments.

Form 10-KSB for the Fiscal Year Ended December 31, 2004

Item 13 - Exhibits and Reports on Form 8-K, page 16

1. We have read your proposed revisions provided in response to
prior
comment 1.  Please further revise your certifications to remove
the
title of the certifying officer from the opening sentence.  In
addition, revise to make reference to the appropriate report (i.e.
annual report on Form 10-KSB/A) and date the certifications as of
the
date of the amendment.

Item 14 - Controls and Procedures Disclosure, page 16

2. We have read your proposed revisions provided in response to
prior
comments 2, 3, 4, 6 and 7.  In future filings, revise to make
reference to the rules defining disclosure controls and
procedures,
Exchange Act Rules 13a-15(e) and 15d-15(e).  In addition, please
confirm to us that such conclusions as set forth in your proposed
revisions, and with the appropriate rule references, were reached
by
your officers as of the end of the period covered by the reports
for
the periods ended December 31, 2004, March 31, 2005, June 30, 2005
and September 30, 2005.

Form 10-QSB for Fiscal Quarter Ended September 30, 2005

Financial Statements

Note 7 - Capitalization, page 12

3. Please tell us how you considered paragraphs 8-10 of SFAS 123
and
EITF 96-18 in accounting for the consulting agreement with Dawson
James Securities, Inc.

      As appropriate, please amend your filings and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please file your cover letter on EDGAR.
Please understand that we may have additional comments after
reviewing your amendment and responses to our comments.

      	You may contact Amanda Sledge, Staff Accountant, at
(202)
551-3473 or the undersigned at (202) 551-3428 if you have
questions.

								Sincerely,

      Rachel Zablow
      Staff Accountant
Mr. F. Dale Markham
REIT Americas, Inc.
November 29, 2005
Page 2

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