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                                   [ANGELCITI
                                 Entertainment
                                      LOGO]

                              9000 SHERIDAN STREET
                            PEMBROKE PINES, FL 33204
                                PH (800) 346-1697
                               FAX (954) 337-2919
                          E-MAIL: EVELYN@ANGELCITI.COM
                            HTTP://WWW.ANGELCITI.COM

Ms. Beverly Singleton
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

RE: RESPONSE TO LETTER DATED NOVEMBER 2, 2005

Dear Ms. Singleton:

     Thank you for your letter and suggestions. We welcome any opportunity to
make the disclosures in our filings more meaningful, concise and clear. In this
regard, we have the following responses to your inquiries.

     1.   Per your suggestion, and despite the fact that we believe that the
          description of our business in the MD&A is sufficient, we intend to
          revise the MD&A. We do not share your view that our MD&A merely
          rehashes what appears in the description of business section of the
          filing, but do acknowledges that there is some repetition. We believe
          that portions of our MD&A relating to the regulatory risks that may
          affect our business bear repeating as such risks directly affect our
          ability to attract new players to our client's website and collect
          gaming proceeds from players. We will, however, attempt to streamline
          any repeated disclosure so that the reader may focus on the most
          potent and salient points and will seek to eliminate information that
          may serve to detract from a reader's understanding, consistent with
          the spirit of FRR-72.

     2.   We have always distinguished net gaming transactions from our revenues
          and pointed out that revenues may not increase if gaming transactions
          improve. We will seek to make this more clear. The disclosure in the
          footnotes to our financial statements will be consistent with the
          disclosure contained in the other portions of the filings.

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     3.   We have consistently described in our filings that our operations and
          those of entities that we have been dependent on, are susceptible to
          significant regulatory risks. These regulatory risks emanate from
          within and without the United States. We believe we have fully
          described regulatory trends and threats of future regulation in our
          filings. In our view, the current threats to our industry are related
          to a player's ability to make payments to an on-line casino. However,
          we offer, on a supplemental basis, our belief that our industry is
          surviving the potential effects of such threatened regulation on the
          processing of gaming transactions. For the foregoing reason, we did
          not think that a breakdown of revenues in the MD&A would be material
          to a reader's understanding of trends or risks affecting our business.
          However, per your suggestion, revenues will now be broken down, in
          tabular form, into those revenues that are attributable to American
          players and shall also be presented as a percentage of total revenues.

     4.   While we believe we have fully explained and described our operations
          in our filings, we will explain in greater detail, both in the MD&A
          and notes to the financial statements, why we are presenting our
          results as those of a casino even though we are not a casino. In a
          nutshell, we feel that such disclosures provide the reader with a
          better understanding as to how we earn revenues and incur expenses.

     5.   The shares were issued as collateral in mid December 2004, however,
          they were not placed in escrow and may be traded by the recipient and
          thus meet the criteria of FASB Statement 128 Footnote 5(c) which
          states they are "issued". The "consideration" for the shares at the
          issuance date in December 2004 is the $300,000 loan receivable to the
          Company by the lender. Please note that the proceeds were received
          just after year-end on January 4, 2005. Similar to treatment of a
          "subscription receivable" the shares are recorded as issued with a
          subscription receivable debit. Since the shares however had a market
          value at the issuance date of $.50 per shares based on the quoted
          trade price, far exceeding the loan amount it was determined to record
          the total value of such shares, $14,164,000 to account for any future
          potential "fee" treatment. In substance, the $300,000 loan receivable
          is inherent in the $14,164,000 deferred amount.

          Although the shares were presented as "issued" they were not treated
          as outstanding for EPS purposes. However, Under FASB Statement 128
          Footnote 5 and paragraph 10 since they are contingently returnable
          they are not included in Basic earnings per share (not outstanding)
          until the contingency is resolved. Please note therefore that these 28
          million shares were not included in the computation of EPS as of
          December 31, 2004 or March 31, 2005 per the financial statements
          footnote 1(M), which we have partially duplicated below:

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          In addition, the lender did not have the option to provide that
          consideration. Without that consideration, the shares would not have
          been provided to the lender. Also, once the shares were issued, only
          the Company was in control of repayment of the $300,000 loan and
          therefore again, consideration was not at the option of the lender.
          Thus, the shares are considered issued but not outstanding for
          accounting purposes.

          Financial Statement footnote 1(M) Excerpt

                  "At December 31, 2004, there were 28,328,000 shares of common
                  stock that are considered dilutive securities outstanding.
                  These shares are contingently returnable. The contingent
                  shares are not included in the computation of Basic EPS. In
                  December 2004, the Company issued those 28,328,000 shares in
                  order t obtain a loan (see Notes 10 (B) (ii) and 15)"

     6.   The issue here is determining the measurement date to value the
          shares. Footnote 10 paragraph 3, states that The $0.50 fair value was
          determined based on the issuance date, which was determined by
          management to be the measurement date. At the issuance date of the
          collateral shares on December 7, 2004 the quoted market price was
          $.50. As an analogy, using EITF 96-18 principles, since the $300,000
          loan and the service of providing the loan was the consideration for
          the shares ( see response to No. 5 above), the counterparty's
          performance was complete and a measurement date was achieved at the
          issuance date.

     7.   Midas Entertainment, Inc. is a related party since our President,
          George Gutierrez, is also the President of Midas. Midas is traded only
          on the pink sheets and our review of such trading volume during 2004
          and trades indicated that the stock was very thinly traded, many days
          at zero volume. Average daily volume was only 925 shares. Out of
          approximately 24 million shares outstanding in Midas at December 31,
          2004 only approximately 1 million were free trading. Angelciti owned
          19% or about 4.6 million shares at December 31, 2004, primarily
          restricted. Therefore, given all the factors including the related
          party relationship, significant blockage effects, restrictions and the
          thinly traded activity we did not believe that the Midas shares had a
          "readily determinable fair value" as indicated in paragraph 3a. of
          SFAS 115. Paragraph 43 of SFAS 115 also emphasizes that only
          securities with "readily determinable" fair values may use SFAS 115.
          If SFAS 115 cannot be applied then the default is APB 18. To use the
          quoted price would have potentially resulted in a material
          overstatement of the investment asset. Accordingly, the value was
          conservatively stated at the original cost basis using the APB 18
          method.

     8.   Midas Entertainment is a related party. Midas and the company agreed
          to terminate the loan agreement and then the Company would purchase
          the shares with the loan and accrued interest due. In substance, the
          loan was repaid with interest and then 3,600,000 shares were purchased
          for $306,246. As this is a related party transaction, we believe it
          would be inappropriate to consider any gain or loss in operations on
          this transaction;

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     9.   FNC was a related party. Footnote 12 discloses why no consideration
          was paid as follows: "In exchange for receiving these services, no
          cash or non-cash compensation for these services was paid by the
          Company to FNC since FNC considered that the increase in volume for
          such transactions for its operations would provide it valuable
          exposure to certain of FNC's service providers. Ultimately, the
          increased volume transacted between FNC, and its service providers on
          behalf of the Company would lead to reduced rates for future services
          with these providers for the Company, and FNC believes this will serve
          as fair consideration for this transaction."

          Since a combination of entities under common control combined both
          companies as if they had operated together since inception, any costs
          to the Company (and related income to FNC) that would have been
          recorded, if the Company determined to do so, would have been
          eliminated in combination for the year ended December 31, 2003 and
          thus there is no financial statement effect whether costs were
          recorded or not. Consideration paid for the acquisition of FNC was
          nominal at $10. During 2003 FNC only had expenses of $2,371 and no
          revenues.

          We take our obligations under the Securities Exchange Act very
seriously and acknowledge our responsibility for the adequacy and accuracy of
the disclosures in our filing. Even though we intend to make revisions to our
filings, such revisions should not be construed as an admission that the
disclosures previously contained in our filings had in any way been
insufficient. We further acknowledge that any corrections or revisions that we
make will not foreclose the Commission from taking any action against us with
respect to our filings and that we may not assert staff comments as a defense in
any proceeding initiated by the Commission or others under federal securities
laws.

         Please do not hesitate to contact the undersigned if you have any
questions or comments.

                                                Very truly yours,

                                                By: /s/ George Gutierrez
                                                    ----------------------------
                                                    George Gutierrez, President
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