SecProbe.io

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      March 18, 2005

Mail Stop 0409

	VIA U.S. MAIL AND FAX (561) 988-9891

Mr. Adam Wasserman
Chief Financial Officer
Genesis Technology Group, Inc
777 Yamato Rd. Suite 130
Boca Raton, FL 33431

Re:	Genesis Technology Group, Inc.
	Form 10-KSB for the year ended September 30, 2004
	Form 10-QSB for the quarter ended December 31, 2004
      File No. 333-86347

Dear Mr. Wasserman:

      We have reviewed your above referenced filings and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents.  As such, all persons who are
responsible
for the adequacy and accuracy of the disclosure are urged to be
certain that they have included all information required pursuant
to
the Securities Exchange Act of 1934.

      Where indicated, we think you should revise your documents
in
response to these comments.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a 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 filing.
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 us at the telephone numbers
listed
at the end of this letter.

Form 10-KSB for the year ended September 30, 2004

Financial Statements and Notes

Marketable Equity Securities, page F-9
1. Please tell us and revise future filings to clarify that your
available for sale investments are recorded at fair value and
further
clarify how fair value is determined when the securities are not
publicly traded and do not have a quoted market value.  Further
clarify the nature of the restrictions on certain of these
securities
and how those restrictions are considered in your valuation
process.
Also describe to us your accounting policy for determining other
than
temporary impairments and include that policy and additional
disclosure, if applicable, in future filings. Refer to SFAS 115
and
EITF 03-1.

Note 3 - Acquisitions, page F-14
2. Please clarify to us in a supplemental response why you did not
file a Form 8-K related to your acquisition of Extrema on
September
8, 2004 to provide the historical and pro forma financial
statements
related to this acquisition.  Refer to Item 310 of Regulation S-B.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please file your response on EDGAR.

	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
for
an informed 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 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.

      You may contact Matthew Dowling, Staff Accountant, at (202)
824-5141 or me at (202) 942-1964 if you have questions.

						Sincerely,

Linda van Doorn
Senior Assistant Chief Accountant

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Genesis Technology Group, Inc.
March 18, 2005
Page 1 of 3

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