SecProbe.io

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<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
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                                   May 9, 2005

Mr. Rufus Decker                                              Via FAX to:  (202)
942-9531
Branch Chief
Division of Corporation Finance
United States Securities and Exchange Commission
Washington, D.C. 20549-0510

Re:     American  Fire  Retardant  Corp.;
        Item  4.02,  Form  8-K;
        Form  10-KSB  for  the  fiscal  year  ended  December  31,  2003;
        Form 10-QSB for the periods ended March 31, 2004 and June 30, 2004;
        File  No.  0-26913

Dear  Mr.  Decker:

     In  response  to  your  letter  dated  April 20, 2005, in connection to the
above-captioned  matters,  we  respond  as  indicated  below.

     In  response to your number 1, an amended 8-K will be filed today including
a brief description of the facts underlying the conclusion that we need to amend
our previous filings to the extent known to us at the time of filing as required
by  Item  4.02(a)  of  Form  8-K.

     In  response to your number 2, this matter was discussed by me with Mr. Gus
Rodriguez,  Staff  Accountant  in  your  office.  We  will  be  amending  the
above-mentioned  filings  as soon as possible after completing the filing of our
current  10-KSB  for  the  year  ended  December 31, 2004 and the 10-QSB for the
quarter  ended  March  31,  2005.  I anticipate that all amended filings will be
completed  and  filed  by  the  end  of  May  2005.

     In  response  to  your  request  toward the end of your comment letter, the
company  acknowledges  the  following:

          -    the  company  is responsible for the adequacy and accuracy of the
               disclosures  in  their  filings;

          -    the  company  understands  that  staff  comments  or  changes  to
               disclosures  in  response  to staff comments do not foreclose the
               Commission  from  taking  any action with respect to the filings;

          -    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.

     While  the  company  acknowledges  the  above,  the  company has always and
continues to attempt to properly state our financial position. After determining
that  our  filings  did  require  restatement, we are striving to accomplish the
restatement  in  the  fastest  time  possible  while  still  assuring  that  the
restatement  will  be  accurate  in  all  respects. Our financial information is
reviewed  quarterly and audited annually and until your comment letters, we felt
we  had  complied  fully  with  those  requirements.

                                   Very truly yours,

                                   Randy W. Betts,
                                   Chief Financial Officer

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