SecProbe.io

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						September 2, 2005

Via Facsimile (772) 231-5947 and U.S. Mail

Kevin R. Keating
President
Qorus.com, Inc.
936A Beachland Boulevard, Suite 13
Vero Beach, FL  32963

Re:	Qorus.com, Inc.
	Schedule 14F-1 filed August 24, 2005
	File No. 005-58071

Dear Mr. Keating:

	We have reviewed the Schedule 14F-1 referenced above and have
the following comments.

Directors and Officers, page 13
1. We note your disclosure regarding the change of control that
occurred on June 22, 2004.  Please provide the information
required
by Item 6(d) of Schedule 14A.

Conflicts of Interest, page 14
2. We note your disclosure that you will engage Keating Securities
to
act as a financial advisor.  We note similar disclosure in the
sections "Board Meetings and Committees" and "Board Meetings;
Nominating and Compensation Committees" that refers to future
events.
Please revise your disclosure to clarify whether you have already
engaged the financial advisors, as appears the case from
disclosure
elsewhere in the filing.  Note that the requirements of Item 7 of
Schedule 14A generally require information with respect to past
events.

Board Meetings; Nominating and Compensation Committees, page 15
3. We note that you do not have a method for security holders to
communicate with your board of directors.  Please provide the
disclosure required by Item 7(h)(1) of Schedule 14A.

Security Ownership of Certain Beneficial Owners and Management,
page
20
4. We note on page 5 that KRM Fund, the Elwin members and Gateway
have agreed to vote their securities to elect director designees
and
approve an amendment to your organizational documents.  Please
tell
us your basis for not including each of these parties` securities
in
the beneficial ownership tables included in this section.  See
Rule
13d-3 for guidance on the determination of beneficial ownership.

Closing Comments

	Please revise your Schedule 14F-1 to comply with the comments
above.  If you do not agree with a comment, tell us why in a
supplemental response letter that you should file via EDGAR as
correspondence.  The letter should note the location in your
amended
disclosure document of changes made in response to each comment or
otherwise.

	Note that we may have additional comments after we review
your
amendment and response letter.  Please indicate how you intend to
disseminate the amended Schedule 14F-1 filed in response to the
comments above.

	In connection with responding to our comments, please provide
a
written statement from Qorus.com, Inc. acknowledging that:

* Qorus.com, Inc. is responsible for the adequacy and accuracy of
the
disclosure in the filing;

* 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

* Qorus.com, Inc. 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.

	Please contact the undersigned at (202) 551-3619 with any
questions.

						Sincerely,

						Daniel F. Duchovny
						Attorney-Advisor
						Office of Mergers and Acquisitions
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Kevin R. Keating
Qorus.com, Inc.
September 2, 2005
Page 1

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

         DIVISION OF
CORPORATION FINANCE

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