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CORRESP
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      Abazias Corresp

    Ms.
      Amy
      Geddes

    Mr.
      David
      R. Humphrey

    U.S.
      Securities and Exchange Commission

    Division
      of Corporate Finance

    Washington,
      D.C. 20549

    Re:
      Abazias Inc. 10-KSB FY end Dec. 31st,
      2004

    Dear
      Ms.
      Geddes and Mr Humprey:

    In
      response to your letter dated July 6, 2005 we herby submit to you supplemental
      disclosure to allow more transparency. As such, we submit the following in
      reference to the above referenced 10-KSB filing. We have provided all responses
      where asked, and will revise disclosure on the items# 2 and 3, where you did
      not
      specifically ask for more information on now, but to expand disclosure as per
      your guidelines.

    1.
      Year
      ended December 31, 2004 vs. Year ended December 31, 2003.

    Our
      sales
      for the year ended December 31, 2004 vs. year ended December 31, 2003 increased
      23% from $1,674,163 to $2,061,958 primarily due to an increase in online
      marketing campaigns, especially with respect to organic search engine rankings.
      In addition, an increased exposure in certain jewelry type portals, assisted
      in
      this increase in revenue.

    Our
      cost
      of sales for the year ended December 31, 2004 vs. year ended December 31, 2003
      increased 16% from $1,574,164 to $1,820,985 due to the corresponding increase
      in
      the amount of diamonds sold for the period. This corresponding increase in
      costs
      is inline, with the proportional increase in additional sales for the
      period.

    Our
      general and administrative expenses for the year ended December 31, 2004 vs.
      year ended December 31, 2003 decreased 47% from $2,345,983 to $1,247,468 due
      to
      a significant reduction in any stock issued to management or consultants versus
      the previous year. The majority of the previous years expenses were as a direct
      result of the merger of Abazias Inc. into Hunno Technologies, the previous
      public entity.

    Our
      interest expense for the year ended December 31, 2004 vs. year ended December
      31, 2003 increased 155% from $2,368 to $6,045 due to an increase in principal
      liability owed to our major stockholder Oscar Rodriguez.

    Accordingly,
      our net loss for the year ended December 31, 2004 vs. year ended December 31,
      2003 decreased 55% from $2,248,352 to $1,012,540 once again primarily due to
      reduction in stock issued to management, and various consultants the as a result
      of Abazias Inc. merger into Hunno Technologies, the previous public
      entity.

    During
      2004, no one supplier provided 10% of total purchases. During 2003, one supplier
      provided 15% of total purchases. All other suppliers provided less than 10%
      of
      total purchases, and we do not foresee this changing to any material
      degree.

    4.
      Revenue Recognition- Return Policy- For most of our products, we offer an
      unconditional 10-day return policy, under which customers desiring to return
      a
      product receive a return authorization by calling our customer service center.
      We have, based on historical return figures, been able to determine that returns
      have never had any material impact on our financial statements, and historically
      been less then than 5% of total sales, based on analyzing historical return
      rates. We therefore expect no more than 5% of sales to be returned witch can
      only occur within 10 days after the sale is made. Returned products are treated
      as merchandise credits and are subject to the same inventory accountability.
      Revenue is recognized when the diamonds are shipped, and returns immediately
      debited against current sales upon any return.

    5.
      Trade
      Up Policy- We have a lifetime trade up policy which provides a guaranteed trade
      up of 80% of the price of the original diamond purchase. This provides our
      customers with the ability and incentive to become and remain our customers
      for
      many years to come. This affords our customers an option that many of our
      competitors will not extend to them. If the buyer exercised his/her trade-in
      right (functionally an option written by us), we would exchange a new diamond
      in
      for the original. Under normal circumstances, any trade up policy exercised
      would be even more profitable than a sale not including an exercised policy.
      This is because, on average we would make our normal markup, in addition to
      getting a discount that is greater than our cost on the diamond traded. It
      is
      conceivably possible, in a catastrophic event to the diamond markets which
      caused the value of diamonds to drop, customers would want to take advantage
      of
      this policy. Our policy is limited to the value of the diamond traded in, being
      close to the value when purchased. As such, we are protected from the functional
      price guarantee as mentioned in EITF 00-24 and FIN 45. Specifically our policy
      is only valid when, the diamond is at least 80% of the wholesale per carat
      price
      at time of purchase, based on published wholesale prices in the Rappaport
      industry publication, which is the de-facto standard for diamond pricing. To
      date, no customers have exercised this policy with us. After reviewing EITF
      00-24 and FIN 45, we would not have any potential financial exposure to account
      for as a result of this policy, since our trade in value requirements based
      on
      current market conditions at the time of trade in, require the diamond to be
      worth 80% of the wholesale carat price, and if it does not, no trade up policy
      is valid.

    6.
      The
      pricing of our products is on a cost plus bases. We purchase our diamonds from
      an array of diamond wholesalers that are geographically dispersed not only
      throughout the United States, but the world. Our standard cost plus pricing
      mark-up to our end customers varies depending on the product purchased. The
      amount of the mark-up depends on a multitude of factors, including but not
      limited to whether they are diamonds, settings, or other jewelry. Such markups
      typically range from as little as 6% for certain types of diamonds, to as high
      as several hundred percent for certain low priced jewelry items, such as a
      bracelet. The vast majority of all our sales are for loose diamonds, in which
      we
      feel we can offer a price advantage over most competitors. The primary reason
      for this advantage is the scalable market in which we operate. We showcase
      over
      sixty thousand diamonds, yet retain the operational overhead of a small to
      medium size jewelry store. As such, our business model has eliminated some
      of
      the traditional mark up layers, and we pass on those savings to our customers.
      Traditionally, the typical supply chain starts from diamond mining, to rough
      brokering, to diamond manufacturing, to diamond wholesaling, to jewelry
      manufacturing, to jewelry wholesaling, to retail inventory, to the end consumer.
      We have eliminated many of these layers by purchasing direct from the diamond
      manufacturer, or the diamond wholesaler, and selling to the consumer directly.
      Most conventional jewelry stores and related outlets will not or cannot sell
      unset stones, because of the desire to add the additional mark up layers, or
      because restrictions on their purchasing channels. Our diamond manufacturers
      and
      wholesalers have a strong desire to sell to us, and facilitate this elimination
      of mark up layers, because we make available for sale such a large amount of
      diamonds on our web-site which attracts many potential customers. Additionally,
      we sort our diamonds primarily by price to an audience well larger than our
      wholesalers would be able to potentially offer themselves. By doing this, a
      symbiotic relationship exists and continues to thrive.

    7.
      and 8.
      Since we do not hold significant inventory, we have reviewed EITF 99-19, to
      clarify if we might be deemed a diamond agent and have to report sales on a
      net
      basis. We clearly do not fit under the appropriate definition as an agent for
      several reasons. Although we hold very little inventory, we purchase all of
      our
      diamonds under our credit facilities with our various wholesalers. This varies
      between many dealers and in same cases, requires us to wire funds before a
      diamond is shipped, to many dealers offering us credit terms of net 30 for
      payment. The customer that purchases a diamond or other product, does so with
      us
      solely, and is never even aware of our wholesaler relationships, and even at
      any
      time we’re aware, could not purchase from them. Consequently, regardless of
      whether we are paid or not for the diamond or other products we sell, we are
      obligated to pay our wholesaler for said product once shipped. We have purchased
      the diamond or product, and the responsibility of said product solely rests
      with
      us, including accepting a return from a customer, even when we in turn might
      not
      be able to return the same diamond to our wholesaler. Regardless of whether
      or
      not the company is deemed an agent, which we clearly are not, we would still
      fulfill all the indicators under EITF 99-19 for gross revenue reporting. We
      are
      the primary obligator in the arrangement, we maintain inventory risk in the
      event the product is returned, price establishment rests solely with us, we
      can
      and do modify the product frequently by mounting diamonds, as well as finishing
      them and other products, we can and do choose among many suppliers, all products
      sold are determined by us, we have physical loss risk, and additionally shoulder
      credit risk. Based on these reasons, we clearly are not an agent, and should
      report revenues on a gross basis.

    9.
      The
      income tax footnote disclosures mentioned in these paragraphs of SFAS 109 are
      not required if the answers are all zeros, as is the case with our
      company.  Abazias has never had, nor is it likely to have in the
      foreseeable future, taxable income.

    We
      understand the company is responsible for the adequacy and accuracy of the
      disclosure in the filings. We further understand 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 further action with respect to
      the
      filing; and that 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.

    Best
      Regards,

    Jesus
      Diaz CFO

    Abazias
      Inc.