SecProbe.io

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August 11, 2005

Larry Spirgel
Assistant Director
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.

Washington D.C. 20549-0406

RE: SEC COMMENT LETTER DATED AUGUST 3, 2005 (FILE NO. 000-30690)

Dear Mr. Spirgel:

We have reviewed the comments included in your letter dated August 3, 2005
regarding the Form 20-F filed by EuroTrust A/S on June 3, 2005. Our responses to
your comments follow.

FORM 20-F FOR FISCAL YEAR ENDED DECEMBER 31, 2004

CONSOLIDATED STATEMENTS OF OPERATIONS; PAGE F-5

1.   In future period, please revise your presentation to comply with SAB Topic
     11:B.

     EUROTRUST A/S RESPONSE

     EuroTrust will revise our presentation of Cost of Revenues in future
periods to read Cost of Revenues (exclusive of depreciation shown separately
below).

2.   Tell us in detail how you concluded that the divestitures of all of your
     related internet business disposed of in 2003 and 2004 should not be
     classified as discontinued operations. In response address EITF 03-13 and
     Paragraph 42 of SFAS 144.

     EUROTRUST A/S RESPONSE

     Paragraph 42 of SFAS 144 requires the disposal of segments to only be
classified as discontinued operations if the following two conditions were met.

(First) the operations and cash flows of the component have been (or will be)
eliminated from the ongoing operations of the entity as a result of the disposal
transaction and

(Second) the entity will not have any significant continuing involvement in the
operations of the component after the disposal transaction.

Paragraph 4 and 5 of EITF 03-13 states that determining whether the cash-flows
have been eliminated is based upon whether the characteristics of the activities
that generate the continuing cash flows are similar to the characteristics of
the activities that generated the cash flows of the component prior to its
disposal.

With the sale of EuroTrust Secure Hosting A/S the Company negotiated that
EuroTrust receive from the buyer the greater of a minimum royalties or a
percentage royalty based upon sales to existing customers at the time of the
sale. With the sale of EuroTrust NetVaulting A/S the

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Company negotiated that EuroTrust receive from the buyer a percentage royalty
based upon sales to existing customers at the time of the sale. EuroTrust's
Management had no further involvement in the operations of the EuroTrust Secure
Hosting A/S and EuroTrust NetVaulting A/S after the sale.

Based upon the sales agreements management judged the characteristics of the on
going royalty received from the sold operations (as provided by paragraph 5 of
EITF 03-13) as being similar in characteristics to the cash flows generated by
these activities prior to their disposal as follows.

1) Whether the nature of the products sold and services provided are similar? -
The nature of the product being sold and services provided in these cases have
not changed.

2) Whether the customers who purchase the products sold and services provided
are similar? Royalties are received based upon sale to existing EuroTrust A/S
customer base at the time of Sale.

3) Whether the geographic region in which products are sold and services are
provided are similar? - The geographic region was Denmark and the Scandinavian
Region of Europe for EuroTrust A/S and the Buyer.

4) Whether the methods used to distribute products and provide services are
similar? - The has been no significant changes by Buyer in distributing the
products and services.

5) Whether the extent of decision-making ability over the operations is similar?
No EuroTrust A/S has no decision-making ability over the sold operations.

6) Whether degree of involvement in the activities is similar (passive versus
active)? EuroTrust A/S has a passive degree of involvement (receipt of
royalties).

7) Whether degree of financial interest is similar (obligation to absorb losses
and ability to receive residual returns)? - While EuroTrust A/S has no further
obligation to absorb losses of these operations EuroTrust A/S is receiving a
residual return in the royalty.

Thus EuroTrust's management has not classified the operations as discontinued in
the Consolidated Statement of operations.

3.   In your disclosure regarding the acquisition of Ideation House ApS, and the
     subsequent divestiture of InAphone A/S, it is unclear to us whether you
     have recorded a gain or loss on the divestiture. Explain to us your
     accounting for the sale of this subsidiary.

     EUROTRUST A/S RESPONSE

On January 1, 2005 the minority shareholders purchased the remaining outstanding
shares of InAphone A/S from EuroTrust A/S for one Danish Krone and agreed to
repay the 2,500,000DKK in intercompany loans. At the time of sale InAphone A/S
had a negative equity of approximately 2,500,000 equal to the intercompany loans
between the EuroTrust A/S and InAphone A/S. Management has estimated that the
2,500,000 will not be collected and established an allowance resulting in a net
gain on sale of InAPhone A/S of zero. As of December 31, 2004, EuroTrust A/S
impaired the goodwill of approximately 965,000 DKK related to purchase of
InAphone A/S (See Note 5 to the 20-F).

GENERAL

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

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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:

     o    the company is responsible for the adequacy and accuracy of the
          disclosure in the filings;

     o    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

     o    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 comment on your filing.

     EUROTRUST A/S RESPONSE

     EuroTrust A/S acknowledges that:

     o    the company is responsible for the adequacy and accuracy of the
          disclosure in the filings;

     o    staff comments or changes to disclosure in response to staff comments
          in the company's filings reviewed by the staff do not foreclose the
          Commission from taking any action with respect to the filing; and

     o    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.

     EuroTrust A/S understands that the Division of Enforcement has access to
all information EuroTrust A/S provides to the staff of the Division of
Corporation Finance in the staff's review of EuroTrust A/S filing or in response
to the staff's comment on EuroTrust A/S filing.

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If you have any further comments or would like to discuss any of the responses
above, please contact me at your convenience.

Sincerely yours,

By /s/ Soren Degn.
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Chief Financial Officer
EuroTrust A/S
+ 45 39 54 00 00

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