SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

      September 1, 2005

Mail Stop 4561

      VIA U.S. MAIL AND FAX (480) 505-0071

Digamber Naswa
Chief Financial Officer
WWA Group, Inc.
2465 West 12th Street
Suite 2
Tempe, AZ  85281

Re:	WWA Group, Inc.
	Form 10-KSB for the year ended December 31, 2004
      Filed April 15, 2005
      File No. 0-26927

Dear Mr. Naswa:

      We have reviewed your filing and have the following
comments.
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 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 numbers
listed
at the end of this letter.

Form 10-KSB

General

1. We note the statement on page 11 of your Form 10-KSB that you
"estimate that as much as 40% of the equipment sold at the Daubai
auctions in 2004 was destined for Iran."  Please discuss for us
whether, and the extent to which, you have actual knowledge of
equipment sold at your Daubai auction being delivered into Iran,
including the facts that lead you to conclude that up to 40% of
the
equipment sold at that auction in 2004 went into Iran.  Describe
the
type and value of the equipment delivered into Iran; the identity
of
the purchasers, including whether, to your knowledge, they are
agencies of, or controlled by, the government of Iran; and your
relationship to the purchasers.  Please provide the same type of
information regarding sales into Iran through any of your other
auctions, and sales through any of your auctions into other
countries
identified by the U.S. State Department as state sponsors of
terrorism.

2. With a view to disclosure, please describe any U.S. licensing
or
other regulatory requirements applicable to your operations with
respect to sales you know or believe are destined for Iran or any
other country that is identified by the U.S. State Department as a
state sponsor of terrorism.  Your answer should include any
licensing
or other regulatory requirements applicable to your operations in
any
such country that is also subject to sanctions administered by the
Treasury Department`s Office of Foreign Assets Control.  Please
include in your description any approvals, discussions or
correspondence with OFAC or other U.S. agencies regulating sales
into
countries that are U.S. State Department-identified state sponsors
of
terrorism.

3. We note the equipment sales that you believe were destined for
Iran and the fact that Iran is subject to OFAC-administered
economic
sanctions and is identified as a state sponsor of terrorism by the
U.S. State Department.  With a view to disclosure, please describe
for us the nature and extent of your current and previous
operations
in, or direct or indirect contacts with, Iran, including through
distributors, consignors and auction participants.  If you believe
that equipment sold was destined for State Department-identified
state sponsors of terrorism other than Iran, please supplement
your
response with a similar discussion with respect to any other such
countries.  In your response, please address the materiality of
any
such operations, contacts or arrangements and your view as to
whether
they constitute a material investment risk for your security
holders.

In preparing your response please consider that evaluations of
materiality should not be based solely on quantitative factors,
but
should include consideration of all qualitative factors that a
reasonable investor would deem important in making an investment
decision, including the potential impact of corporate activities
upon
a company`s reputation and share value.

4. Please describe for us whether any of the transportation or
industrial equipment sold through your auctions have a military
purpose or, to the best of your knowledge, understanding and
belief,
can be put to military use.

Organization and Significant Accounting Policies, page F-8

5. Please tell us why realized and unrealized foreign exchange
differences arising on translation are recognized in the income
statement.  If you have determined that the functional currency of
your entity is the United Arab Emirates Dirham and your reporting
currency is the U.S. Dollar, you would translate your financial
statements into U.S. Dollar and translation adjustments are not
included in the determination of net income but are reported
separately and accumulated in a separate component of equity.  For
reference see SFAS 52.

*    *    *    *

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  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 comment, 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 filing;

* staff comments or changes to disclosure in response to staff
comments 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.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your amendment that keys your
response to our comments and provides any requested supplemental
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 responses to our
comments.

      You may contact James Webster, Staff Accountant, at (202)
551-
3446 or me, at (202) 551-3486 if you have questions.

						Sincerely,

Daniel L. Gordon
Accounting Branch Chief
WWA Group, Inc.
September 1, 2005

3

</TEXT>
</DOCUMENT>