SecProbe.io

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      November 30, 2005

Via U.S. Mail

Alfred Lam
Chief Executive Officer
Pacific CMA, Inc.
C/O Airgate International Corp.
153-04 Rockaway Blvd.
Jamaica, New York 11434

RE:		Pacific CMA, Inc.
		Form 10-K for The Fiscal Year Ended December 31, 2004
		Response Letter dated September 29, 2005

Dear Mr. Lam:

      We have reviewed the above filing and response letter and
have
the following comment.  We have limited our review of your Form
10-K
to disclosures relating to your contacts with countries that have
been identified as state sponsors of terrorism, and will make no
further review of the Form 10-K.  Our review with respect to this
issue does not preclude further review by the Assistant Director
group with respect to other issues.  At this juncture, we are
asking
you to provide us with supplemental information, so that we may
better understand your disclosure.  Please be as detailed as
necessary in your response. After reviewing this information, we
may
or may not raise additional comments.

General -

We note that in your letter dated September 29, 2005, you state
that
you do "not have any past or current contracts, directly or
indirectly, with . . . any boycotted countries" and "nor has [the
company] any materials, supplies, component and goods transported
to
or arranged for transport to, from or in a boycotted country."  We
note also that Appendix B to your letter identifies Sudan as a
country with respect to which you received revenue during fiscal
2004.  In light of the fact that Sudan has been identified by the
U.S. State Department as a state sponsor of terrorism and is
subject
to economic sanctions administered by the U.S. Treasury
Department`s
Office of Foreign Assets Control, please describe for us the
extent
and nature of your past and current contacts, directly or
indirectly,
with Sudan, including the types of materials, supplies,
components,
and goods, you have transported or arranged to transport to, from,
or
on behalf of, Sudan or any Sudanese entity.

Discuss for us the materiality to you of your contacts with Sudan,
and whether those contacts constitute a material investment risk
for
your security holders, in light of the potential impact upon your
reputation and share value of your having business contacts with a
country identified as a state sponsor of terrorism and subject to
U.S. economic sanctions imposed, in part, as a result of its
continued support for international terrorism.  Provide us with
both
your conclusions and underlying analysis.

With regard to the issue of reputational risk and potential impact
on
share value, we note that Arizona and Louisiana have adopted
legislation requiring their state retirement systems to prepare
reports regarding state pension fund assets invested in, and/or
permitting divestment of state pension fund assets from, companies
that do business with countries identified as state sponsors of
terrorism;  Illinois, New Jersey and Oregon have adopted
legislation
requiring reporting of interests in, or divestment from, companies
that do business with Sudan, and similar legislation has been
proposed by several other states; and Harvard University, Stanford
University, Dartmouth College, and the University of California
system have all adopted policies prohibiting investment in, and/or
requiring divestment from, companies that do business with Sudan.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
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 filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; 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 filings or in response
to
our comments on your filings.

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.

								Sincerely,

								Cecilia D. Blye, Chief
								Office of Global Security
Risk

cc: 	Robert Perez
		Gusrae, Kaplan, Bruno & Nusbaum PLLC
		120 Wall Street
		New York, NY 10005

		Max Webb
		Assistant Director
		Division of Corporation Finance

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