SecProbe.io

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                                 Qorus.com, Inc.
                       936A Beachland Boulevard, Suite 13
                              Vero Beach, FL 32963
                                 (772) 231-7544
                               (772) 231-5947 fax

                                September 7, 2005

VIA EDGAR AND FACSIMILE

Daniel F. Duchovny, Esq.
Attorney-Advisor
Office of Mergers and Acquisitions
Securities and Exchange Commission
Washington, DC 20549

            Re:   Qorus.com, Inc.
                  Information Statement Pursuant to Section 14(f) of
                  the Securities Exchange Act of 1934 and Rule 14f-1
                  thereunder Filed August 24, 2005
                  File Number 005-58071
                  --------------------------------------------------------------

Dear Mr. Duchovny:

            On behalf of Qorus.com, Inc. (the "Company"), we respond as follows
to the Staff's comments received on September 2, 2005 under letter dated
September 2, 2005 relating to the above-captioned Information Statement.
Captions and page references herein correspond to those set forth in your
letter. Please note that for the Staff's convenience, we have recited each of
the Staff's comments and provided the Company's response to each comment
immediately thereafter.

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.

      The Information Statement filed August 24, 2005 addresses the proposed
change of control which will be effected upon the closing of the Exchange
Agreement dated as of August 11, 2005. Your comment addresses a change of
control transaction that was completed June 22, 2004 and was fully disclosed in
a 14f-1 Information Statement filed with the SEC on June 10, 2004. We do not
believe additional disclosure in this current Information Statement on a change
of control transaction that occurred over one year ago and has been fully
disclosed in a separate Information Statement is required nor beneficial to the
overall disclosure of the current proposed change of control transaction.

<PAGE>

Daniel F. Duchovny, Esq.
September 7, 2005
Page 2

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 disclosures 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.

      Disclosures regarding the proposed engagement of Keating Securities to act
as a financial advisor are found in the sections "Proposed Change of Control
Transaction," "Conflicts of Interest," and "Certain Relationships and Related
Party Transactions." Each disclosure clearly indicates that Keating Securities
will be engaged by the Company at or prior to the Closing of the Exchange
Agreement. The engagement of Keating Securities is a condition to the Closing of
the Exchange Agreement. We further believe that the disclosure of the proposed
engagement of Keating Securities is a material disclosure despite the fact that
it is a future event (i.e., a condition to the closing of the proposed change of
control transaction). Following the closing of the transactions under the
Exchange Agreement, the Company intends to file a Current Report on Form 8-K, in
the time required by SEC rules, disclosing the appointment of Keating Securities
as the financial advisor with the financial advisory agreement being included as
an exhibit thereto.

      The disclosures in the sections "Board Meetings and Committees" and "Board
Meetings; Nominating and Compensation Committees" that refer to future events
were intended to be statements of fact also covering past events. However, we do
not view any disclosure deficiency in our Information Statement with respect to
this comment to be material.

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.

      Our current disclosure states that the shareholders may suggest director
nominees to any member of the Board and further describes the type of
information that should be submitted. However, the Board does not have a formal
process for security holders to send communications to the Board. As explained
in our Information Statement, the Board does not believe a formal process is
appropriate in this case since the management and directors of the Company are
the same persons and any communications from security holders would be brought
to the Boards' attention by virtue of the co-extensive capacities served by
Kevin R. Keating as our sole officer and director. We have no employees and all
information sent to our principal office listed in our periodic reports and
filings are received and handled by Mr. Keating. We believe that our current
disclosure satisfies Item 7(h)(1) of Schedule 14A.

<PAGE>

Daniel F. Duchovny, Esq.
September 7, 2005
Page 3

Security Ownership of Certain Benefcial 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 organization's 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.

      KRM Fund, the Elwin Members and Gateway will, as a condition to Closing of
the transactions under the Exchange Agreement, enter into a voting agreement to
vote their shares of the Company's voting securities: (i) to elect the
Management Designates and KRM Designate to the Company's board for a period of
one year following the Closing and to vote for such other persons that may be
designated by Shushun Feng to fill any vacant position on the board of directors
(other than KRM Designate), and (ii) to approve an increase in the number of
authorized shares of the Company's common stock from 50,000,000 to 150,000,000,
the Reverse Split and the change of the Company's corporate name (collectively,
the "Actions").

      The voting agreement will further provide that if any such party fails to
vote its shares to approve each of the Actions, such party has granted to
Shushun Feng proxy to vote their shares to approve such Actions. As such,
Shushun Feng has no voting power over such party's shares with respect to any
matters other than the Actions. The agreement among the parties to vote their
shares for designated directors does not give any other party the power to vote
or direct the voting of such shares.

      Due to the limited and conditional nature of Shushan Feng's power to vote
the shares solely to approve the Actions, we do not believe that KRM Fund, the
Elwin Members and Gateway form a group which requires that their shares be
aggregated for purposes of the beneficial ownership rules under Rule 13d-3.
Accordingly, we believe that the beneficial ownership tables included in the
Information Statement are adequate and appropriate.

      In view of the foregoing responses, we respectfully submit that no
amendments to our Information Statement filed August 24, 2005 are necessary or
should be required.

      The Company acknowledges that:

      o     The Company is responsible for the adequacy and accuracy of the
            disclosure in the filings;

      o     Staff comments or changes to disclosures 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

<PAGE>

Daniel F. Duchovny, Esq.
September 7, 2005
Page 4

      o     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.

      If you have any further questions or comments based on our response set
forth above, please kindly contact me as soon as possible.

                                                Very truly yours,

                                                /s/ Kevin R. Keating
                                                Kevin R. Keating
                                                President and Director
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