SecProbe.io

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July 1, 2005

Via Facsimile and (561) 659-0701 and U.S. Mail

Michael Harris
1555 Palm Beach Boulevard
West Palm Beach, FL 33401

Re:	Smartvideo Technologies, Inc. Preliminary Consent Statement
of
Forte Capital Partners, LLC
Schedule 14A filed June 21, 2005, File No. 000-26809

Dear Mr. Harris:

	We have reviewed the above-referenced filing and have the
following comments:

General
1. Although you refer to this document as a "Consent Statement,"
you
are using it as both a consent and a proxy card. We view the
consent
and proxy solicitations as separate solicitations in some critical
respects. For example, the delivery of a proxy to the company in
connection with its annual meeting (which you state may be held in
August) would not standing alone revoke a prior-dated proxy
granted
to you. Because of these practical issues, we permit the use of
combined solicitation materials for both the proxy and consent
solicitations, with the following procedural safeguards:

(i)   a separate Schedule 14A and 14C for the respective proxy and
consent solicitations must be filed on EDGAR. The consent
statement
must satisfy all of the disclosure requirements of both Schedules;
and

(ii)  each solicitation requires a separate form of proxy or
consent.
We also encourage the use of a different color or style to avoid
shareholder confusion and further differentiate the separate
solicitations.
2. See comment 1 above concerning joint materials for both a proxy
and consent solicitation. As you know, the company has not yet set
the record date for any upcoming meeting of shareholders. We are
of
the view that steps should be taken to ensure that all
shareholders
solicited subsequent to the setting of that record date are
furnished
with the disclosure required by Schedule 14A. This will generally
require a supplement to the Consent Statement. Please confirm your
understanding in your response letter.
3. The use of a joint proxy/information statement also raises
disclosure issues. For example, if the company holds its annual
meeting in August as anticipated, it will likely involve only the
election of directors and perhaps some other matters presented by
management. The other proposals for which you are requesting
proxies
or consents may not appear on management`s card. Please clarify
this
in your disclosure. In addition, you should discuss the effect of
granting a consent to you, but also providing a proxy to the
company.
For example, discuss whether granting the company a later-dated
proxy
will revoke a consent to you.
4. All statements of belief must be characterized as such in your
filing, and must be supported by appropriate factual background
materials that appear in the consent solicitation itself or are
provided to the staff on a supplemental basis. Please provide an
"annotated" version of the consent solicitation accompanied by the
appropriate supporting materials underlying the factual
allegations
you make. For example, some of the matters that should be
supported
include (a) the revenue figures for the years ended December 31,
2004
and 2003; (b) the net loss figures for the same periods; and (c)
the
fees for professional services paid by the company for the same
periods. This list is not meant to be all-inclusive.
5. Rule 14a-9 prohibits statements which "directly or indirectly
impugns character, integrity or personal reputation, or directly
or
indirectly makes charges concerning improper, illegal or immoral
conduct or associations, without factual foundation." On page 2 of
the consent solicitation, you accuse the current board of "blatant
breaches of the duty of loyalty to stockholders" and "egregious
waste
of corporate assets." While you may disagree with actions taken by
the board, we believe these and other inflammatory allegations are
improper and may run afoul of Rule 14a-9, particularly where they
are
not stated as beliefs. Please revise.
6. In a prominent place at the beginning of your consent
statement,
please identify the participants in this solicitation, as defined
in
Instruction 3 to Items 4 and 5 of Schedule 14A.
7. Given the prior involvement of some of your nominees with
Smartvideo and the ongoing litigation between one nominee and the
company, as well as Forte Capital`s prior work for the company and
its claims for compensation, it appears that the participants in
your
solicitation have unique interests and potential conflicts of
interest in this solicitation specific to their history with the
company. Because of this fact, and because of the importance of
this
kind of information to an informed voting decision by
shareholders,
please add a section at the forepart of the consent statement
discussing these matters in a clear, concise and complete manner.
Rather than repeating disclosure that appears in several places
throughout the document, consider relocating it to this new
section.
Your existing disclosure should also be expanded to address how
Forte
and its affiliates will handle those conflicts and conflicts of
interest going forward. For example, according to the chart on
page
6, Forte claims to be owed cash and securities for services
rendered
to the company. If its nominees are elected to the board, will
such
cash and securities be paid to Forte?

8. We note that your second proposal is to repeal any amendment to
the company`s bylaws adopted since April 29, 2005 and any
amendment
adopted before that time but not filed with the SEC.  To your
knowledge, has any such amendment been adopted?  If so, please
describe the amendment or amendments that may be affected by the
adoption of your proposal.

Why Should I Consent, page 2
Waste, page 4
9. Please see comments 4 and 5 above. Provide us with support, on
a
supplemental basis, for the assertion that Mr. Walsh was required
to
and attempted multiple times to obtain the referenced information
from Mr. McNeil.  Further, you should describe exactly what
information you reference.
10. Please explain how the amount of $800,000 for 23 months of
services owed to Mr. McNeil`s company is "a concern of a possible
illegal transaction."  Further, explain how it may "be an example
of
management enriching themselves at the expense of the
stockholders."
For example, do you have any information that confirms the extent
and
nature of the services provided?
11. In a supplemental response, please explain your calculation of
the compensation value owed to Interim CFO Solutions LLC to be at
$4.186 million.  In such explanation you should state the closing
price of the company`s common stock on November 29, 2004, which
you
use for your calculation.
12. Please provide the basis to support your statement that the
"Company`s sizable professional fees which included the fees of a
major national law firm which acts as its securities counsel make
it
appear that this $800,000 liability was at best a waste of the
Company`s assets."  It appears that the services of securities
counsel would be very different from the services provided by
Interim
CFO Solutions LLC.  Please amend your disclosure to support your
statement and provide more information with respect to the types
of
services provided by the entities you compare.

Interest of Certain Persons in the Solicitation, page 6
13. Please see our comment above regarding the advisability of
relocating participant interest information in a single section at
the beginning of this document. We emphasize the critical nature
of
information about the participants` and their affiliates`
interests
in this solicitation, especially as they differ from the interests
of
shareholders generally. As such, this type of information must be
prominently and clearly disclosed.
14. Summarize the services Forte was obligated to perform under
the
terms of its consulting agreement with the company. In addition,
state the length of that agreement under its terms. Your current
disclosure indicates that Forte terminated it after four months,
but
is not clear whether this was early termination (see our next
comment).
15. Briefly discuss the basis for Forte`s termination of its
consulting agreement with the company. For example, did the
agreement
provide for termination upon 30 days notice? In addition, explain
why
Forte chose to terminate the agreement.
16. Considerably expand the discussion of the $740,000 owed by
Forte
to the company under Amendment 1 to the Securities Purchase
Agreement. For example, state the date on which this sum became
due
(it is not entirely clear whether May 13, 2005 was the triggering
event), whether Forte has paid or intends to pay any such sum, and
if
not, on what basis it is contesting the payment of the $740,000.
17. The registration statement filed by Smartvideo and amended on
June 30, 2005 apparently registers the resale of a significant
number
of shares issued to Forte. Please discuss in this section. Your
new
disclosure should state how many shares Forte will own going
forward,
and the estimated proceeds it will realize as a result of the sale
of
these shares.
18. Please supplementally provide the pleadings in each lawsuit
referenced in the consent solicitation and the similar document
for
the arbitration proceeding initiated by Mr. Seifert.
19. With respect to the lawsuit brought by Forte against the
company
and Richard E. Bennett, Jr., expand to describe the relief sought
and
to name the court which will hear the suit.

Amendment of Bylaws to Set the Size of the Board at Four, page 7
20. Despite your disclosure here and elsewhere in the consent
statement, it is not entirely clear how you will handle the fact
that
the size of the board is apparently uncertain and the fact that
you
have nominated more individuals than the current size of the
board.
That is, if this to expand the board fails, but you are successful
in
electing at least one nominee, which nominee will be elected? Will
it
be the one with the most votes? This does not appear to jibe with
the
disclosure on the consent itself (in the asterisked disclosure
after
Proposal 3), which appears to indicate that the nominees will be
"prioritized" in the order in which they appear on the consent.
Please clarify.
Removal of Directors, page 8
21. Given the extensive allegations of fraud, corporate waste,
etc.
you make against the company and its director, explain why your
fourth proposal seeks to remove Mr. Bennett (and the other members
of
the board, if any) "without cause." Explain the significance of
removing directors without cause versus for cause. For example,
will
this trigger any severance payments under their respective
employment
agreements with the company?

Consequences of Partial Approval of the Proposals, page 15
22. In your response letter, please update us on the status of
your
efforts to obtain the stockholder list from the company for
purposes
of this solicitation and compliance with your obligations under
Rule
14f-1.

Closing Information

      Please revise your Schedule 14A to promptly comply with our
comments.  If you do not agree with a comment, then tell us why in
your response.  If the information you provide in response to our
comments materially changes the information that you have already
provided to security holders, disseminate the revised materials in
a
manner reasonably calculated to inform them of the new
information.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
Since the participants in this solicitation 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 participants acknowledging that:

* the participants are responsible for the adequacy and accuracy
of
the disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and

* the participants 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.

      Direct any questions to me at (202) 551-3257, or in my
absence,
to Christina Chalk at (202) 551-3263.  You may also contact me via
facsimile at (202) 772-9203.  Please send all correspondence to us
at
the following ZIP code:  20549-3628.

      Very truly yours,

	Celeste M. Murphy
      						Special Counsel
Office of Mergers
and Acquisitions

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Michael Harris, Esq.
July 1, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0303

         DIVISION OF
CORPORATION FINANCE

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