SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>globaldig8kltrtandy10042004.txt
<DESCRIPTION>10/4/2004 COMMENT LETTER #1; ITEM 4.01, 8-K; HOUSER
<TEXT>

October 4, 2004

William J. Delgado
Chief Executive Officer
Global Digital Solutions, Inc.
10970 Old Placerville Road, Suite 107
Sacramento, California  95827

RE:  	Form 8-K Item 4.01 filed October 4, 2004
	File # 0-26361

Dear Mr. Delgado:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, we will consider your explanation as
to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  After
reviewing this information, we may or may not raise additional
comments.  In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your disclosure.
After reviewing this information, we may or may not raise additional
comments.

	Please understand that the purpose of our review process is to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.  We
look forward to working with you in these respects.  We welcome any
questions you may have about our comments or on any other aspect of
our review.  Feel free to call us at the telephone number listed at
the end of this letter.

1. We note that on January 8, 2004, a merger was completed in which
Pacific Comtel, Inc. was the accounting acquirer of Global Digital
Solutions, Inc. for which the new company continued to be called
Global Digital Solutions, Inc.  Furthermore, on March 25, 2004, a
merger was completed in which the new Global Digital Solutions, Inc.
(i.e., the former Pacific Comtel, Inc.) was the accounting acquirer of
Creative Beauty Supply, Inc.  The information require by Item 304 of
Regulation S-B should be provided for the accounting acquirer`s
previous two fiscal years and the subsequent interim period through
dismissal.  As such, please amend your Item 4.01, Form 8-K to reflect
the following:
* State whether the accountant`s report on Pacific Comtel, Inc.`s
financial statements for either of the past two years, June 30, 2002
and June 30, 2003 contained an adverse opinion or a disclaimer of
opinion or was qualified or modified as to uncertainty, audit scope or
accounting principles; and a description of the nature of each such
adverse opinion, disclaimer of opinion, modification or qualification.
This would include disclosure of uncertainty regarding the ability to
continue as a going concern in the accountant`s report.  Refer to Item
304(a)(1)(ii) of Regulation S-B for guidance.
* State whether during the registrant`s two most recent fiscal years,
June 30, 2002 and June 30, 2003, and the subsequent period through the
date of resignation, July 1, 2003 through September 24, 2004, there
were any disagreements with the former accountant on any matter of
accounting principles or practices, financial statement disclosure, or
auditing scope or procedure, which disagreement(s), if not resolved to
the satisfaction of the former accountant, would have caused it to
make reference to the subject matter of the disagreement(s) in
connection with its reports.  Refer to Item 304(a)(1)(iv) of
Regulation S-B.

2.   Please remove references to Regulation S-K in your Item 4.01 of
Form 8-K and replace with the appropriate references to Item 304 of
Regulation S-B, as you an S-B filer with the U.S. Securities and
Exchange Commission.

3. Please confirm to us that Russell Bedford Stefanou Mirchandani LLP
is auditing your Form 10-K for the year ended June 30, 2004, or revise
your disclosures to clarify which firm is auditing your June 30, 2004
Form 10-K.

4. Please revise the last sentence of Item 4(b) to comply with the
disclosure requirements of Item 304(a)(2) of Regulation S-B.

5. To the extent that you make changes to the Form 8-K to comply with
our comments, please obtain and file an updated Exhibit 16 letter from
the former accountants stating whether the accountant agrees with the
statements made in your amended Form 8-K.

*****

Please file your supplemental response and amendment via EDGAR in
response to these comments within 5 business days of the date of this
letter.  Please note that if you require longer than 5 business days
to respond, you should contact the staff immediately to request
additional time.  Direct any questions regarding the above to the
undersigned at (202) 942-1989.

	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.

	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.

Sincerely,

Tracey Houser
Staff Accountant
William J. Delgado
Global Digital Solutions, Inc.
October 4, 2004
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

       DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>