SecProbe.io

July 6, 2005

Via US Mail and Facsimile

Mr. Jesus Dias
Chief Financial Officer
Abazias, Inc.
5124 SW 91st Terrace, Suite A
Gainseville, FL 32608

Re: Abazias, Inc.
 Form 10-KSB for the year ended December 31, 2004
 Commission File Number:  000-23532

Dear Mr. Diaz:

We have reviewed the above referenced filing and have the following comments.  We have
limited our review to the financial statements and related disclosures included within these
documents.  Understand that the purpose of our  review process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filings.

Where expanded or revised disclosure is reque sted, you may comply with these comments in
future filings.  If you disagree, we will consider your explanation as to why our comments are
inapplicable or a revision is unnecessary.  In so me of our comments, we may ask you to provide
us with supplemental information so we may be tter understand your disclosure.  Please be as
detailed as necessary in your explanation.

We look forward to working with you in thes e respects and welcome any questions you may
have about any aspects of our review.

* * * * * * * * * * * * * * * * * * * * * * *
Item 6. Management’s Discussion and Analysis or Plan of Operation

Results of Operations

Year Ended December 31, 2004 vs. Y ear Ended December 31, 2003, page 22

1. From your presentation of Results of Operations, it appears there have been material changes
in each income statement line item presented.  Your explanations provided in this section do

Mr. Jesus Diaz
Abazias, In c.
July 6, 2005
Page 2

not provide enough information about these changes for the reader of the financial statements
to understand and evaluate your business.  Please revise the explanations  presented to clearly
and completely explain the facts and circumst ances surrounding each change.  Include a draft
of your intended disclosure with  your response.  Refer to th e guidance in Item 303 (b) of
Regulation S-B.

Liquidity and Capital Resources, page 27

2. On page 12, you assert your belief that you have and can generate sufficient cash resources to
operate for the next 12 months.  Discuss this  assertion in Management's Discussion and
Analysis, and include the specific reasons underlying your belief.  In this discussion, provide
an estimate of your monthly cash  operating expenses and indicate the level of sales needed to
provide adequate resources to fund these expenses.

3. You state that your majority stockholder adva nces money on an as-needed basis.  Please
expand this disclosure to indi cate that, notwithstanding his wi llingness to make advances in
the past, your majority stockholder has no legal obligation to make further advances in the
future.

Financial Statements

Note 1 – Summary of Significant Accounting Policies, page F-6

Revenue Recognition
4. We note from your disclosure here and elsewh ere in your filing that you have a standard 10-
day return policy.  Supplementally explain to us and revise your disclo sure to indicate how
you calculate and account for expected returns.  If such returns cannot be reasonably estimated, you should defer revenue recognition until the 10-day return period has expired.
See SFAS 48 for guidance.

5. We note from disclosure on page 6 that you extend an 80% lifetime trade-up policy on all
diamond purchases.  Supplementally explain to us and expand your disclosure to discuss how
you have assessed and recorded the fair value of  these guarantees.  Refer to the guidance in
EITF 00-24 FIN 45.

6. Supplementally tell us how you set the price of  your products.  For example, on page 6, you
state that an efficient price structure has been established that  has created incentives for your
suppliers to provide you with advantageous pr ices.  Please explain to us how your price
structure was established, and whether there is  any standard relations hip between the prices
of diamonds to your customers and the amounts you pay to your diamond suppliers.

7. We note that you do not hold diamonds in inve ntory and that most of the diamonds you
display on your web site are owned by your suppliers.  We also note that you require
payments from customers in advance.  These fa cts suggest you may be acting as an agent for

Mr. Jesus Diaz
Abazias, In c.
July 6, 2005
Page 3

your diamond suppliers and, if so, sales of such  diamonds should be reported on a net basis
(that is, the amount received from the cust omer less the amount paid to the diamond
supplier).  Please refer to EITF 99-19 to determine whether you should report revenues on a
gross or net basis.  In this regard, consideration should be gi ven to the possibility that your
jewelry sales should be reporte d on a gross basis and diamond sales should be reported on a
net basis.  If you conclude that gross revenue reporting is appropriate  for all of your product
sales, supplementally provide us with your analys is of each of the indicators set forth in EITF
99-19.

8. Regardless of whether you use gross or net re porting, or a combinati on thereof, please
expand the description of your revenue recognition policy to disclose the reasons why you
believe your policy is appropriate.

Note 5 – Income Taxes, page F-6

9. Please revise your income tax note to present all disclosures required by paragraphs 41-48 of
SFAS 109.  Specifically, your disclosure should be  revised to present current and deferred
tax expense or benefit by juri sdiction, a reconcilia tion using either percentages or dollar
amounts of the reported amount of income tax e xpense attributable to continuing operations
for the year to the amount of income tax e xpense that would result from applying domestic
federal statutory rates to pr etax income from continuing operations, and the reason you
believe a valuation allowance is necessary.  Pl ease include a draft of your proposed revised
disclosure with your response.

* * * * * * * * * * * * * * * * * * * * * * *

We urge all persons who are responsible for the a ccuracy and adequacy of the disclosure in the
filings reviewed by the staff to be certain that  they have provided a ll information investors
require.  Since the company and its management  are in possession of a ll 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 disclo sure in the filings;
‚ staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose th e 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 federa l securities laws of  the United States.

In addition, please be advised th at the Division of Enforcement has access to all information you

Mr. Jesus Diaz
Abazias, In c.
July 6, 2005
Page 4

provide to the staff of the Division of Corporat ion Finance in our review  of your filing or in
response to our comments on your filing.

Please file your response to our comments via EDGAR within ten business days from the date of
this letter.  Please understand that we may have additional comments after reviewing your
response.  You may contact Amy Geddes at  202-551-3304 or me at 202-551-3211 with any
concerns as I supervised the review of your filing.

        S i n c e r e l y ,

        David R. Humphrey
        B r a n c h  C h i e f