SecProbe.io

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                                  NEXICON, INC.
                             400 Gold SW, Suite 1000
                              Albuquerque, NM 87102

July 13, 2005

VIA EDGAR AND U.S. MAIL
-----------------------

Larry Spirgel, Assistant Director
United States Securities and Exchange Commission
450 Fifth Street, N.W., Mail Stop 3561
Washington, D.C. 20549

Re:   Nexicon, Inc.
      Form 10-KSB for the Fiscal Year Ended December 31, 2004
      Filed May 9, 2005

      Form 10-QSB For the Fiscal Quarter Ended March 31, 2005
      File No. 0-30244

Dear Mr. Spirgel:

      This letter has been prepared in response to your request for Nexicon,
Inc. ("Nexicon" or the "Company") to respond to the comments of the United
States Securities and Exchange Commission (the "SEC") as memorialized in your
July 8, 2005 letter to me concerning the above-referenced filings by Nexicon
(the "Comment Letter")

      The following are the Company's responses to the Comment Letter, which
responses follow a recitation of the relevant comment.

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

Note 1. Summary of Significant Accounting Policies, page F-6
------------------------------------------------------------
Segment information, page F-8
-----------------------------

COMMENT 1.  We note your response to our previous comment 2 and your new
            disclosure in your footnotes. In future filings please add a segment
            discussion to results of operations in accordance FRC Section
            506.06. Include a discussion of your measure of profit or loss for
            each reportable segment.

RESPONSE:   In future filings, the Company will add a segment discussion to
            its discussion of results of operations in accordance with FRC
            Section 506.06, and will also include a discussion of the Company's
            measure of profit or loss for each reportable segment. The Company
            has included the requested information in the Registration Statement
            on Form SB-2 that the Company intends to file with the SEC within
            1-2 days from the date hereof (the "Registration Statement"). Please
            refer to page 26-27 of the Registration Statement, "Management
            Discussion and Analysis."

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Mr. Larry Spirgel
July 13, 2005
Page 2

Note 13. Acquisition of Assets and Loss on Asset Impairment, F-17
-----------------------------------------------------------------

COMMENT 2.  We note your response to our previous comment 4 and 5. However
            we did not see disclosure in your Form 10-KSB/A which indicates fair
            values equal historical cost. Further, you did not respond to our
            comment with regards to the specific nature of your in-process
            research and development. As a result, we are re-issuing our
            previous comments 4 and 5.

RESPONSE:   The Company has amended its Form 10-KSB to provide the requested
            disclosures, which indicate fair values equal historic cost (the
            "Amended Form 10-KSB"). The Amended Form 10-KSB is being filed with
            the SEC concurrently with this Response Letter. The requested
            disclosure is also contained on page F-26 of the Registration
            Statement.

            With regard to your comment concerning the specific nature of the
            Company's in-process research and development, the Company has
            included the requested information on page F-26 of the Registration
            Statement and also in the Amended Form 10-KSB.

            Specifically, Note 13 to the Consolidated Financial Statements as of
            December 31, 2004 and 2003 now provides that the assets and
            liabilities of Pluto Communications International, AS ("Pluto"),
            which were assumed by the Company were recorded at fair value, which
            equals the historical cost basis of Pluto; and further, that there
            have been no in-process research and development costs incurred by
            Pluto since the date of acquisition.

            Note 13 to the Consolidated Financial Statements as of December 31,
            2004 and 2003 now also provides that there have been no in-process
            research and development costs incurred by Central Solutions, Inc.
            since the date the Company issued 10,000,000 shares of its common
            stock in exchange for 35% of Central Solutions common stock.

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Mr. Larry Spirgel
July 13, 2005
Page 3

      Should you have any questions concerning this Response Letter, please
contact me at 505-248-0000.

Sincerely,

/s/ Daniel Urrea
----------------
Daniel Urrea
Chief Financial Officer

cc:      Clayton Parker, Esq., Kirkpatrick & Lockhart Nicholson Graham LLP
         (via facsimile)

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