SecProbe.io

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                          BRAVERMAN INTERNATIONAL, P.C.
                          Certified Public Accountants
                               1255 McDonald Drive
                               PRESCOTT, AZ 86303
                                CELL 602-881-3870
                      PHONE 928-771-1122, FAX 928-777-8378
                                hiluv007@aol.com

Steven Jacobs
Accounting Branch Chief
Securities and Exchange Commission
Washington, D.C. 20549

The following are responses to your letter of September 16, 2005 which are being
rendered in advance of the amendments  you requested.  We have complied with the
matters in the first two items,  however, we trust that our explanations for the
last two items  will be helpful in  supporting  the basis for the  presentations
originally  including in the  previous  filings by us, and that you would concur
with our position on them.

Balance Sheet page F-2
----------------------

Response
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1. We have made the changes  necessary  to comply with SFAS 144 and deferred the
gain on the  disposition  of the  subsidiary  until the date of closing in March
2005.

Statement of operations, page F-3
---------------------------------

Response
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2. As a result of complying with the above item, the gain has been eliminated as
of December 31, 2004 and  reported in the Form 10-QSB as of March 31, 2005.  The
subsequent events footnote to the financial  statements  included in Form 10-KSB
now contains the disclosure and details of the net  liabilities  assumed by OFG,
which is the basis for the gain, now deferred.

Note 1 - Summary of Significant Accounting Policies, page 14
------------------------------------------------------------

Response
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3.FASF 128, paragraph 54 states that nominal issuances are  recapitalizations in
substance and should be reflected in a manner  similar to a stock split or stock
dividend for which  retroactive  treatment is required in computing  EPS. In the
SEC  disclosures  checklists  published  in  2004 by  Miller,  SAB  Topic  4D is
discussed at 31.12 and it references  not only that nominal  issuances  apply to
registration  statements  but to subsequent  filings with the SEC. We regard par
value as a nominal value for which all shares were issued.

Response
--------
4. In connection with the  consideration  received by the Company for 10 million
shares,  the  Company's  stock  did not have  any  trading  history  nor did the
reseller  agreement  exchanged  for the issuance of that stock have any previous
history of value.  It was created by OFG and CCWW to enable MDS the  opportunity
of selling dealership  licenses in certain countries.  No consideration was paid
to CCWW to acquire the agreement.  Accordingly,  the basis for the $10,000 value
of the agreement was the cost of creating it of approximately  $10,000 which OFG
paid in  connection  with legal fees and costs  including  travel to Canada.  We
regard the historical cost of creating the agreement to be the only  measurement
of value in the circumstances,  and that is why it was used. There was no market
for this  asset  previously,  and the  subsequent  losses  of the  Company  have
supported the fact that there was little value to it.

APB 29  paragraph  4b.  states that its opinion does not apply to "a transfer of
nonmonetary  assets solely  between  companies or persons under common  control,
such as between a parent  company and it  subsidiary  or between two  subsidiary
corporations  of the same parent,  or between a corporate  joint venture and its
owners".  Therefore the criteria of that opinion which includes objective values
for an asset acquired or stock issued are not applicable.  Only the transferee's
historical cost basis of the asset acquired by the Company seemed to be the best
measurement of value to be assigned to the asset acquired and the SEC's Topic 5G
supports  this,  albeit  no IPO  was  involved,  but  there  was a  registration
statement filed which subsequently became effective .

We have attached the restated financial statements, footnotes and the opinion as
of December 31, 2004 and the restated financials and footnotes to be included in
an amended Form 10-QSB as of March 31, 2005 as reference to the above  inquiries
and responses,  and would greatly  appreciated your expedited  remarks to all of
the above items so that MDS and we can avoid further  amendments  after the ones
to be made.

The Form  10-QSB as of June 30,  2005 will also be  amended  to  include  in the
current  year,  the year to date amended  presentations  necessary to report the
gain which is now being reported during the first quarter of 2005.

Sincerely,

/s/ Ivan Braverman
---------------------------
Ivan Braverman, president
Braverman International, P.C.

Enclosures:

Audit report, consolidated financial statements and footnotes as of December 31,
2004
Financial statements and footnotes as of March 31, 2005
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