SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 3561
		June 29, 2005

Mr. Irwin Horowitz, President
Evolve One, Inc.
1000 Clint Moore Road, Suite 101
Boca Raton, FL  33487

	Re:      Evolve One, Inc.
			Form 10-KSB for Fiscal Year Ended December 31, 2005
			Filed March 31, 2005
			Forms 10-QSB for Fiscal Quarter Ended March 31,
2005
			Filed June 7, 2005
			File No. 0-26415

Dear Mr. Horowitz:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Where indicated, we think you should
revise the filing in response to these comments.  If you disagree,
we
will consider your explanation as to why our comment is
inapplicable
or revision is unnecessary.  Please be as detailed as necessary in
your explanation. In some of our comments, we may ask you to
provide
us with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call me at the telephone number
listed
at the end of this letter.

Form 10-KSB for the Fiscal Year ended December 31, 2004

Financial Statements

Notes to Consolidated Financial Statements

Note 4.  Marketable Equity Securities, F-13

1. We noted that you have recorded unrealized losses related your
available-for-sale securities.  Please provide an analysis of the
factors you considered in determining whether the impairment of
these
securities was other-than-temporary.  Your response should address
the following:

* Clarify the nature of the companies you have invested in, the
type
of investment (i.e. equity securities, etc.), and whether the
investment is in a publicly traded security;
* Identify each security (by name and ticker) and tell us how long
each has been in a loss position;
* Where there is little or no trading volume on your publicly
traded
investment securities, tell us how you have determined fair value.
In this regard, tell how you determined fair value for those
securities that ware not publicly traded and how you have
concluded
that SFAS 115 is the appropriate authoritative literature.

2. For those securities in which an other-than-temporary
impairment
has not been recognized, please revise to provide the required
disclosures of EITF 03-1 (specifically paragraphs 20 and 21).

* * * * *

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please file your letter on EDGAR under the
form type label CORRESP.  Please understand that we may have
additional comments after reviewing your amendment and responses
to
our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities 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 a company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

	In connection with responding to our comments, 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 filing;

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

      You may contact Angela Halac, Staff Accountant at (202) 551-
3398 or Hugh West, Accounting Branch Chief at (202) 551-3872 if
you
have any questions.

Sincerely,

Tia Jenkins
Senior Assistant Chief Accountant
Office of Emerging Growth Companies

??

??

??

??

Mr. Irwin Horowitz
Evolve One, Inc.
June 29, 2005
Page 3

</TEXT>
</DOCUMENT>