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Mail Stop 3651

      June 28, 2005

Via U.S. Mail and Facsimile

Gary F. Kimmons
President, Chief Executive Officer, and Chief Financial Officer
M Power Entertainment, Inc. (formerly GK Intelligent Systems,
Inc.)
432 Park Avenue South, 2nd Floor
New York, NY 10016

RE:	M Power Entertainment, Inc. (formerly GK Intelligent Systems,
Inc.)
			Form 10-KSB for the Fiscal Year Ended December 31,
2004

      File No. 000-22057

Dear Mr. Kimmons:

      We have reviewed your filing and have the following
comments.
We have limited our review to only financial statements and
related
disclosures and do not intend to expand our review to other
portions
of your document.  Where indicated, we think you should revise
your
document in response to these comments and comply with the
remaining
comments in all future filings.  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.  In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

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

Item 6. Management`s Discussion and Analysis or Plan of Operation

1. In future filings please expand your MD&A section to include an
introductory section or overview to provide a balanced, executive-
level discussion that identifies the most important themes or
other
significant matters with which management is concerned primarily
in
evaluating your financial condition and operating results. Your
introduction or overview should include, but not be limited to,
the
following:

* Include economic or industry-wide factors relevant to the
company;
* Serve to inform the reader about how the company earns revenues
and
income, and generates cash;
* to the extent necessary or useful to convey this information,
discuss your lines of business, locations, and principle products
and
services ( but an introduction should not merely duplicate
disclosures in the Description of Business section); and
* provide insight into material opportunities, challenges and
risks,
such as those presented by known trends and uncertainties, on
which
your executives are most focused for both the short and long term,
as
well as the actions they are taking to address these
opportunities,
challenges and risks.

	See FR-72 for guidance.

Critical Accounting Policies

2. We remind you that under existing MD&A disclosure requirements,
a
company should address material implications of uncertainties
associated with the methods, assumptions and estimates underlying
the
company`s critical accounting measurements. In this regard, please
revise future filings to include a "Critical Accounting Policies"
section within MD&A that includes a discussion of your most
critical
accounting policies and estimates which should include but not be
limited to revenue recognition, the determination of your
allowance
for doubt accounts, your policies for evaluating potential
impairments in goodwill and long-lived assets and the
determination
of your valuation allowance for the deferred tax assets. Your
discussion should address the factors as to how you arrived at the
estimate(s), how accurate the estimate/assumption has been in the
past, how much the estimate/assumptions has changed in the past
and
whether the estimate/assumptions is reasonably likely to change in
the future. Additionally, you should consider the following when
determining what other items should go in to your critical
accounting
policy disclosure:

* the nature of the estimate or assumptions is material due to
levels
of subjectivity and judgment necessary to account for highly
uncertain matters or the susceptibility of such matters to change;
and
*  the impact of the estimates and assumptions on financial
condition
or operating performance is material.

Such disclosure should supplement, not duplicate, the description
of
accounting policies that are already disclosed in the notes to the
financial statements. See FR-60 and FR-72 for guidance.

Liquidity, page 18

3. We note from this disclosure and in Note 12 to your
consolidated
financial statements that you have committed to raise operating
and
growth capital for your newly acquired subsidiaries (i.e.
WhiteCanyon
$4,000,000; CoraZong $1,500,000 and R.S $2,500,000).  In this
regard,
please expand your Liquidity section to include in detail your
plan
to raise such capital. Additionally, if such plan has not been
consummated by the respective parties involved, please explain
your
alternatives, if any, or state the consequences of not raising
such
capital.

Item 7. Financial Statements

Consolidated Statements of Stockholders` Equity, page F-6
Note 7.  Commitments and Contingencies, page F-19
Consulting Agreements, page F-21

4. We note that during your fiscal year ended December 31, 2004
the
majority, approximately 63%, of your common stock was issued as
consideration for services. Based on the significance of these
transactions, please provide us with and revise your notes to your
financial statements to include a disclosure describing by each
individual entity the amount of common stock issued, price, nature
of
service, and confirm if the entity is or is not a related party.
We
may have further comments upon receipt of your response.

5. Reference is made to your issuance of shares in exchange for
services received for each period presented.  Supplementally tell
us,
with a view toward expanded disclosure in future filings, how you
valued the transaction (i.e., based on the fair value of the
shares
issued or the services received).

Note 1.  Organization and Summary of Significant Accounting
Policies

f.   Revenue Recognition, page F-15

6. Expand your disclosure to indicate whether you record revenues
associated with your staffing business on a gross or net basis.
In
this regard, supplementally tell us, with a view toward expanded
disclosure in future filings, how you met the criteria set forth
in
EITF 99-19 supporting your accounting treatment.  We may have
further
comments upon review of your response.

m. Stock-Based Compensation, page F-18

7. Please revise your notes to the financial statements to include
the disclosures required by paragraph 2(e) of SFAS No. 148.

Note 2. Notes Payable, page F-18

8. We note from your disclosure that you have various unsecured
notes
payable totaling $396,421, of which $232,421 was with related
parties, bearing imputed interest rates from 10% to 18% per annum.
In
this regard, please revise future filings to include the
disclosures
required by paragraph 2 of SFAS No. 57.

Note 3. Accounts Payable, page F-18
Note 4. Accrued Liabilities, page F-19
Note 9. Gain on Release and Extinguishment of Debt, page F-22

9. We note from your disclosure in note 3, note 4 and note 9 that
during the year ended December 31, 2003 and 2004 you recognized a
gain of $2,220,782 and $966,581, respectively due to the fact that
these amounts had been outstanding for periods exceeding the
statue
of limitations of four years and were determined to have been
extinguished and thus written off.  Supplementally tell us, with a
view toward expanded disclosure, whether the transactions related
to
these liabilities were with related parties (if not already
disclosed.)  To the extent that the transactions were with related
parties such as the transactions related to the write-off of
$31,347
in accrued related party interest expense during the year ended
December 31, 2003 as disclosed in Note 4, supplementally tell us
why
the related gains (losses) were not recorded as capital
transactions
(i.e., additional paid-in capital).  See footnote 1 to paragraph
20
of APB No. 20 and the analogous guidance set forth in Staff
Accounting Bulletin Topic 5:T.  Additionally, please provide us
with
a summary of, and disclose in your future filings, all related
party
accounts payable, notes payable, accrued liabilities and accrued
interest at December 31, 2003 and 2004 and the nature of your
relationship with each related party as required by paragraph 2 of
SFAS No. 57.

10. We note from your disclosure that during 2003 and 2004 you
extinguished debt in exchange for common stock recognizing a gain
of
$85,788 and loss of $25,000 during 2003 and a gain of $26,298
during
2004.  In this regard please provide us with, and disclose in your
future filings, the number of shares issued in each transaction,
the
related fair market value of the stock issued and your method used
to
determine the fair market value of your common stock at the time
of
each debt extinguishment.  In addition, supplementally tell us how
you determined that the fair market value of your common stock was
more clearly evident than the fair market value of the payable
settled supporting your accounting for these transactions.  We may
have further comments upon review of your response.

Note 6. Going Concern, page F-19

11. Revise future filings to disclose management`s "viable plan"
which has the capability of removing the threat to your
continuation
of your company as a going concern in accordance with Section
607.02
of the Financial Reporting Codification.  The "viable plan" should
include appropriate and prominent disclosure of your plans to
overcome your financial difficulties.  Similarly, expand your
disclosure in MD&A.

Note 7.  Commitments and Contingencies, page F-19

12. Reference is made to the second paragraph.  If it is
reasonably
possible that the outcome of the uncertainty may result in a
liability that would be material to an investor, please revise
future
filings to disclose the range of reasonably possible loss or made
clear statement that a range cannot be estimated.  See paragraph
10
of SFAS 5 and advise or revise future filings, as appropriate.

Note 10. Acquisitions, page F-23

Stellar Software Network, Inc.
Ascendant TSG

13. We note from your disclosure that you acquired all of the
issued
and outstanding shares of common stock of Stellar, in exchange for
$191,000 paid in the form of the 8,025,211 shares of your common
stock.  In this regard please, provide us with, and revise future
filings to explain, the basis for determining the fair market
value
of the above mentioned common stock. See paragraph 51 (d) of SFAS
No.
141 for guidance.  Also, we note from your disclosure in the third
paragraph of Note 1(a) and in the first paragraph of Item 9.01 of
your Form 8-K/A dated June 16, 2004 that the common shares that
you
issued in the acquisition of Stellar were restricted.  In this
regard, supplementally tell us, and revise future filings to
disclose, the nature of the restriction(s).

14. We note from your disclosure that you deemed the primary value
of
Stellar to be its customer lists, management experience and
expertise, and network of professional and technical contacts.
You
also state that these factors contributed to your agreement to
acquire Stellar for a purchase price exceeding the value of
Stellar`s
net assets.  In this regard, it appears that you have acquired
specific intangible assets, which meet the criteria for
recognition
apart from goodwill (e.g. customer lists, non-contractual customer
relationships, employment contracts, etc.).  Therefore, please
revise
your financial statements (including the pro forma information
included on pages F-24 through F-26) to allocate part of your
purchase price to the fair market value of the intangibles that
you
purchased.  See paragraph A14 of SFAS No. 141 for guidance.
Further,
expand the notes to the financial statements to disclose your
accounting treatment.  Also, include the disclosures required by
paragraphs 52(a) and (b) of SFAS No. 141.

15. Reference is made to your unaudited pro forma condensed
statements of operations for the year ended December 31, 2004 and
December 31, 2003, which gives effect to your acquisition of
Stellar
on page F-24.  Please delete these pro forma statements since you
have reflected the impact of your acquisition of Stellar in the
unaudited pro forma condensed statements of operations on page F-
26.

16. Reference is made to your unaudited pro forma condensed
statements of operations for the year ended December 31, 2004,
which
gives effect to your acquisitions of Ascendant TSG and Stellar on
page F-26.  Please revise these pro forma financial statements to
reflect the impact of Ascendant TSG`s results of operations for
the
period January 1, 2004 through August 12, 2004 (i.e., the period
prior to your acquisition of Ascendant TSG).  In this regard, you
may
revise the Ascendant TSG column to only reflect Ascendant TSG`s
results of operations for the period January 1, 2004 through
August
12, 2004 or you may delete Ascendant TSG `s results of operations
for
the period August 13, 2004 through December 31, 2004 since those
results are already reflected in your historical results of
operations for the year ended December 31, 2004.  Similarly,
revise
your pro forma disclosures regarding your acquisition of Stellar.
In
addition, please delete the combined GK, Stellar column and
historical earnings per share information for Ascendant TSG and
Stellar since this information is not deemed meaningful.  Also,
include pro forma earnings per share information (basic and
diluted)
in accordance with paragraph 55 of SFAS No. 141.

17. Reference is made to your unaudited pro forma condensed
statements of operations for the year ended December 31,
2004,which
gives effect to your acquisitions of Ascendant TSG and Stellar on
page F-26.  Delete the write-off of goodwill in the amount of
$1,584,865 as reflected in the pro forma adjustment column as this
write-off should already be included in your historical statements
of
operations reflected in the third column.  Please make the
appropriate revisions.

18. We note from your disclosure that you acquired all of the
issued
and outstanding shares of common stock of TSG, in exchange for
$1,500,000 paid in the form of the 42,857,153 shares of the
Company`s
common stock.  In this regard please provide us with and revise
future filings to explain the basis for determining the fair
market
value of the above mentioned common stock. See paragraph 51 (d) of
SFAS No. 141 for guidance.

Note 11. Impairment of Goodwill

19. We note from note 6 that you do not have significant amounts
of
cash or other material assets, nor do you have an established
source
of revenues to cover your operating costs and to allow you to
continue as a going concern.  Additionally, you state that there
is
no assurance that you will be successful in raising the needed
capital or that there will be sales of your software.
Furthermore,
you have a deficit in working capital and recurring operation
losses.
In consideration of the above factors, please provide us with a
summary of material relevant facts, assumptions, and estimates you
considered in your goodwill impairment analysis related to the
goodwill associated with the Stellar acquisition and further
explain
to us why you concluded that no impairment of goodwill was
necessary
for the periods presented in the filing as it relates to the
goodwill
associated to the Stellar acquisition. Finally, you state in note
1(i) that you follow SFAS No. 121, we advise you that SFAS No. 121
has been amended and superseded by SFAS No. 142 and SFAS No. 144,
respectively.  In this regard, please revise your notes to the
consolidated financial statements to include your a