SecProbe.io

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								October 12, 2005

Room 4561

Walter K. Weisel
Chief Executive Officer
17105 San Carlos Boulevard, Suite A1651
Fort Myers, Florida 33931

Re:  	Innova Holdings, Inc.
	Registration Statement on Form SB-2/A
      Filed September 30, 2005
      File No. 333-127368

      Form 10-KSB/A for Fiscal Year Ended December 31, 2004
      Filed on July 29, 2005
      Form 10-QSB/A for Fiscal Quarter Ended March 31, 2005
      Filed on July 29, 2005
      Form 10-QSB for Fiscal Quarter Ended June 30, 2005
      Filed on August 22, 2005
      File No. 0-33231

Dear Mr. Weisel:

	This is to advise you that we have limited our review of the
above-referenced filings to the responses to our comment letter
dated
September 2, 2005 and other matters addressed in the comments
below.
Please respond to our comments that pertain to the Form 10-KSB/A,
Form 10-QSB/A and Form 10-QSB within 10 business days of the date
of
this letter.

Registration Statement on Form SB-2, as amended

Prospectus Cover Page
1. We refer you to comment 2 of our letter dated September 2,
2005.
We note disclosure in this section that states "[w]ith the
exception
of Cornell Capital Partners, Monitor and the other selling
shareholders, which are each an "underwriter" within the meaning
of
the Securities Act of 1933, no other underwriter or person has
been
engaged to facilitate the sale of shares of common stock in this
offering."  However, only Cornell Capital Partners is named as an
underwriter in the "Plan of Distribution" section.  Please advise
or
revise accordingly.

Risk Factors page 5
2. Consider whether risk factor disclosure is appropriate to
address
the ineffective [disclosure] controls and procedures and internal
controls over financial reporting you describe in the proposed
revisions to your periodic reports.

Selling Stockholders, page 13
3. Please advise as to any affiliation between Monitor Capital,
Inc.
and Cornell Capital Partners.

Signatures, page II-11
4. Please revise, if true, to indicate that Mr. Gartlan is also
signing as Principal Accounting Officer or Controller.  See
Instruction to Signatures to Form SB-2.

Supplemental response with proposed revisions to your Form 10-
KSB/A
for the fiscal year ended December 31, 2004 filed on July 29, 2005
5. We note that in your first paragraph, after defining disclosure
controls and procedures you state your officers concluded your
"controls and procedures were ineffective."  Please revise to
indicate, if true, that your disclosure controls and procedures
were
ineffective.  In responding to this comment and the following
comments please also revise disclosure in all the above-referenced
periodic reports.
6. Please disclose here, or elsewhere as appropriate, such as your
"Management`s Discussion and Analysis" section, whether there are
any
material costs associated with the "corrective" measures discussed
in
your response to comment 4 of our letter dated September 2, 2005.
7. We reissue comment 5 of our letter dated September 2, 2005, in
part.  Please revise to expressly identify all material weaknesses
and any significant deficiency that, when combined with other
significant deficiencies, is determined to be a material weakness.

Supplemental response with proposed revisions to your Form 10-QSB
for
the fiscal quarter ended June 30, 2005 filed August 22, 2005
8. We note you only reevaluated your internal controls over
financial
reporting and disclosure controls and procedures after receipt of
a
letter from the SEC Staff dated June 22, 2005.  Please advise why
you
believe that your disclosure controls and procedures were
effective
on June 30, 2005.
9. We reissue comment 7 of our letter dated September 2, 2005 in
part.  It appears from the timeline provided in the proposed
disclosure that there may have been changes to your internal
controls
over financial reporting that occurred during the last fiscal
quarter
that materially affected, or is reasonably likely to materially
affect your internal control over financial reporting.  Please
revise
to provide the disclosure pursuant to Item 308(c) of Regulation S-
B
or advise why there were no such changes.

							*  *  *

      If you have any questions, please contact Adam Halper at
(202)
551-3482.  If you need additional assistance you may contact me at
(202) 551-3730.

							Sincerely,

							Barbara C. Jacobs
							Assistant Director

cc:  	Robert L. Davidson, Esq.
	400 Park Avenue, Suite 1430
	New York, NY 10022
	Fax: (212) 277-7401

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Walter K. Weisel
Innova Holdings, Inc.
October 12, 2005
Page 1

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