SecProbe.io

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Mail Stop 4561

      October 3, 2005

      VIA USMAIL and FAX (212) 308 - 6433

Mr. Daniel Myers.
Chief Executive Officer
Carsunlimited.Com, Inc.
444 Madison Avenue, 19th Floor
New York, New York 10022

      Re:	Carsunlimited.Com, Inc.
		Form 10-KSB for the year ended 12/31/2004
      Filed on 4/12/2005
      File No. 333-43748

Dear Mr. Daniel Myers:

      We have reviewed your above referenced filing 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 document.  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.

      In our comments, we may ask you to provide us with
information
so we may better understand your disclosure.  Please be as
detailed
as necessary in your explanation.  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-K FOR THE YEAR ENDED DECEMBER 31, 2004

Financial Statements and Notes

Statement of Cash Flows

Supplementary Schedule of Non-cash Transactions, page F-5

1. We note that you have amortized the entire amount of the debt
discount related to the beneficial conversion feature on your
notes
payable on the date of issuance.  Tell us the maturity dates of
your
notes payable and explain to us how you have considered the
guidance
in paragraph 19 of EITF 00-27 in determining the appropriate
accounting treatment.

Item 14.  Controls and Procedures

2. We note that the company performed an evaluation of the
effectiveness of the design and operations or your disclosure
controls and procedures within 90 days prior to your filing the
Form
10-KSB and subsequent Forms 10-QSB for the periods ended March 31,
2005 and June 30, 2005.  Pursuant to Item 307 of Regulation S-B as
amended by Release No. 33-8238: Management`s Reports on Internal
Control over Financial Reporting and Certification of Disclosure
in
Exchange Act Periodic Reports, effective August 14, 2003, such
evaluation should be performed as of the end of the period covered
by
the report.  Tell us how you complied with such requirements or
advise us.

*    *    *    *

      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 responses on EDGAR.  Please understand that we
may
have additional comments after reviewing your responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosures 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 disclosures,
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
disclosures in the filings;

* staff comments or changes to disclosures 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 Wilson K. Lee, at (202) 551-3468 or me at
(202)
551-3413 if you have questions.

								Sincerely,

      Cicely Luckey
      Branch Chief
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Daniel Myers
Carsunlimited.Com, Inc.
October 3, 2005
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