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<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>tr.txt
<DESCRIPTION>BURNETT: LETTER DATED 10/15/04 RE 4.01 8-K FILED 10/12/04
<TEXT>

Mail Stop 0308
							October 15, 2004

Jeffrey Sass
President
Trust Licensing, Inc.
950 South Pine Island Road, Suite A150-1094
Plantation, FL  33324

	RE:	Trust Licensing, Inc. (f/k/a New Mountaintop Corporation)
		Item 4.01 Form 8-K filed October 11, 2004
            	File No. 0-18689

Dear Mr. Benson:

       We have the following comments with regard to the above
referenced filing.  We welcome any questions you may have about our
comments.  Feel free to contact us at the telephone numbers listed at
the end of this letter.

1. Please revise to state if you dismissed Dorra Shaw or if they
resigned.  Also state the date of this event.  See Item 304(a)(1)(i)
of Regulation S-B.

2. In paragraph (c) you state that Dorra Shaw reported on financial
statements for a two year period.  We assume you mean each of the two
years in the two year period ended December 31, 2004.  Please confirm
our understanding or advise.  You may want to consider revising the
disclosure to clarify this point.  See Item 304(a)(1)(ii) of
Regulation S-B.

 	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to be
certain that they have provided all information investors require.
Since the company and its management are in possession of all facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

Jeffrey Sass, President
Trust Licensing, Inc.
October 15, 2004
Page 2

	In connection with responding to our comments, please provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company 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 addition, please be advised that the Division of Enforcement has
access to all information you provide to the staff of the Division of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

	Please provide any supplemental information requested above
within 10 business days from the date of this letter.  The
supplemental information should be filed as correspondence on EDGAR.
The amendment requested by the above comments above should be filed
as promptly as possible and should be reviewed by the former
accountants.  The letter required by Exhibit 16 should cover the
revised disclosures.  Any questions regarding the above should be
directed to me at (202) 942-1809, or in my absence, to Robert Benton
at (202) 942-1811.

							Sincerely,

							Robert Burnett
						            Staff Accountant

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