SecProbe.io

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                             RICHARDSON & PATEL LLP
                            10900 Wilshire Boulevard
                                    Suite 500
                              Los Angeles, CA 90024
                            Telephone (310) 208-1182
                            Facsimile (310) 208-1154

                                 January 7, 2005

Via Electronic Transmission and Federal Express
---------------------------------

United States Securities and Exchange Commission
Office of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C., 20549
Attention:        Mr. Max A. Webb, Assistant Director, and
                  Mr. Daniel Morris, Attorney-Advisor

         Re:      Logistical Support, Inc.
                  Registration Statement on Form SB-2
                  File No. 333-120520, filed November 15, 2004

Dear Mr. Webb:

      On behalf of Logistical Support, Inc. (the "Company"), we enclose for
filing under the Securities Act of 1933, as amended, Amendment No. 1 to the
above-referenced registration statement (the "Registration Statement") together
with exhibits thereto.

      Amendment No. 1 to the Registration Statement contains revisions that have
been made in response to comments received from the staff ("Staff") of the
Securities and Exchange Commission in their letter dated December 13, 2004. Set
forth below is the Company's response to the Staff's comments. We have
reproduced the Staff's comments in bold type and have followed each comment with
our response. References in this letter to "we," "our" or "us" mean the Company
or its advisors, as the context may require. Clean and marked copies of
Amendment No. 1 to the Registration Statement are being provided supplementally
with a copy of this letter for the convenience of the Staff.

Table of Contents

1.    Please note that the table of contents must immediately follow the cover
      page. Your "Special Note Regarding Forward-Looking Statements" should
      appear later in the prospectus. Please revise the prospectus as
      appropriate. Refer to Item 502 of Regulation S-B.

<PAGE>

Office of Corporate Finance
Securities and Exchange Commission
Attn: Mr. Max A. Webb and Mr. Daniel Morris
January 7, 2005
Page 2

In response to Staff's comments, the table of contents has been moved to
immediately follow the cover page. The "Special Note Regarding Forward-Looking
Statements" has been moved to proceed the Risk Factors.

The Company, page 1

2.    Please revise to include a brief description of what you do to earn funds.
      Include your earnings/losses and revenues for the most recent audited
      period and interim stub. That financial snapshot will provide a context to
      help understand the other information you provide. Also, disclose here
      that you will need to raise additional capital to fund your operations and
      quantify the amount you need, if practicable.

In response to Staff's comments, we have made the corresponding changes to the
Registration Statement to include the summary data and descriptions.

3.    We suggest a Recent Events section in the summary detailing the
      controversy involving Triumph Components.

In response to Staff's comments, we have made the corresponding changes to the
Registration Statement to include a Recent Events section in the summary section
that includes information concerning the dispute with Triumph Components. We
have also updated the corresponding Risk Factor and Legal Proceedings section.

The Offering, page 1

4.    Disclose here the amount of the cash fee you paid Hunter.

In response to Staff's comments, we have made the corresponding change to the
Registration Statement to include the cash fee paid to Hunter.

Risk Factors, page 1

5.    In the next amendment replace the all block capital headings with bold
      headings to improve readability.

In response to Staff's comments we have made the corresponding changes to the
Registration Statement. We note for staff that our "edgar" service provider
advises us that the software they use does not "show" the bold feature in the
filing documents. However, this change has been made to the text.

<PAGE>

Office of Corporate Finance
Securities and Exchange Commission
Attn: Mr. Max A. Webb and Mr. Daniel Morris
January 7, 2005
Page 3

We are dependent upon a single customer... all of your investment, page 2

6.    Please revise this risk factor to more specifically identify and discuss
      the types of occurrences that would disqualify the company from bidding on
      government contracts.

In response to Staff comments we have made the corresponding changes to the
Registration Statement. We also respectfully note for Staff that an entire,
separate Risk Factor discusses certifications and qualifications for bidding and
performing military contracts.

We have recently been unable to rely upon payment by the Unites States
government....deplete our available working capital, page 4

7.    Please provide a clearer account of the reasons for the government's
      decision to deny you progress payments.

In response to Staff comments we have made the corresponding changes to the
Registration Statement.

We supplementally inform Staff, that while the Company believes that the key
reason for the denied or delayed progress payments is our history of late
performance on certain contracts, we cannot verify this with the United States
government. The government is not compelled to provide any specific guidance as
to why progress payments are delayed or denied, unless they are specifically
rejecting delivery of a product (which is not the case in our recent contract
performance) or are dissatisfied with our progress under contract. As described
in the Registration Statement, past performance is a critical factor in being
awarded government contracts, based on our likelihood of completion on time and
within specifications. Similarly, we suspect the government is hesitant to make
periodic payments to us if the agency is concerned that our performance will be
late; the government may wish to obtain further performance on the contracts
prior to making payments to us. In a sense, the government wants to "see" our
performance before payment is made, even though they have agreed under contract
to review requests for periodic progress payments.

Although we cannot control the government's denial or complete lack of response
to our requests for progress payments, we must nonetheless move forward with
performance. As discussed in the corresponding Risk Factor, this can place a
strain on our cash flow. Accordingly, we believe that the government's denial of
our requests for periodic payments stems from past performance which was
sometimes late, however we have no way to verify or confirm the government's
reasons since they are not obligated to tell us. We have attempted to clarify
this point in the Registration Statement.

<PAGE>

Office of Corporate Finance
Securities and Exchange Commission
Attn: Mr. Max A. Webb and Mr. Daniel Morris
January 7, 2005
Page 4

International expansion of our business may not be possible in light of changing
regulations and international law, page 6

8.    You state that you have "historically sold products in many countries
      outside the United States." However, on page 2 you disclose that 99% of
      your revenue is from products sold to the U.S. government. Please clarify.

In response to Staff comments we have made the corresponding changes to the
Registration Statement. We supplementally advise Staff that the majority of our
historical sales to foreign military organizations were made through an
affiliate entity of our Company and that all such sales date back approximately
five years. Foreign sales are not a material portion of our revenue and do not
constitute a key element of our strategy.

Our officer and directors own or control approximately 53.19%...market price of
your common shares, page 8

9.    Please expand the discussion of this risk to include more detailed
      disclosure regarding the potential adverse effect of concentrated share
      ownership by management on certain transactions that may provide a
      premium, or other benefit, to minority shareholders.

In response to Staff comments we have made the corresponding changes to the
Registration Statement. We also advise Staff that corrections have been made to
the beneficial ownership table. However, these changes do not modify the
percentage ownership of directors, officers and "named executive officers" as
originally calculated.

A large number of common shares are issuable...depress the prevailing market
price for our shares, page 8

10.   We note that this risk factor combines the risk of dilution and the risk
      of depressed market prices due to increase sales on the market. Please
      consider revising the prospectus to discuss in separate risk factors each
      of the above risks.

In response to Staff comments we have made the corresponding changes to the
Registration Statement

The Securities Purchase Agreement, page 10

11.   With a view toward disclosure, please supplementally describe the nature
      of any relationships that may exist between the Company and the selling
      shareholders or their principals.

<PAGE>

Office of Corporate Finance
Securities and Exchange Commission
Attn: Mr. Max A. Webb and Mr. Daniel Morris
January 7, 2005
Page 5

In response to Staff comments, we supplementally inform Staff that to our
knowledge, the Company and its officers and directors have no relationship with
Hunter World Markets, the selling shareholders (other than Richardson & Patel
LLP) or their respective partners, managers and directors. The sole relationship
with Hunter World Markets and the selling shareholders relates to the private
placement completed on October 1, 2004. We have requested information from the
selling shareholders (other than Richardson & Patel LLP) in the form of a
Selling Shareholder Questionnaire. The completed questionnaires do not show any
relationships with the Company outside of the investment.

Richardson & Patel LLP is our general corporate and securities counsel.
Richardson & Patel LLP is counsel to the Company and does not advise or
represent any of the Company's officers or directors individually.

General, page 10

12.   We note that the Nov. 11, 2004 price of your stock was $1.80 per share.
      Please add an explanation of why your board approved the sale on Sept.
      29th at Twenty cents a share.

In response to Staff comments we have made the corresponding changes to the
Registration Statement

13.   Also consider adding to the recent developments section a mention of the
      Nov. 11th sale and price per share.

In Response to Staff comments the transaction with the selling shareholders is
now disclosed and under a newly inserted "recent developments" section under the
"Summary" section at the front of the Registration Statement.

14.   Because there appears to be a new investment decision, whether to take
      cash or stock, still to be made by the selling shareholders, there appears
      to be uncertainly about whether the private placement has closed. Please
      supplementally provide us with your legal analysis.

In response to Staff's comments, we submit that the private placement closed
prior to the filing of the Registration Statement. Any issuance of cash or stock
would only be made in the event that the Company did not meet any of the
objective requirements of Section 2(b) of the Registration Rights Agreement.
That provision relates to the timing of the filing or effectiveness of the
Registration Statement, the trading price of the Company's shares and other
factors beyond the control of the selling shareholders. Such payments would be
made as "penalty" only if the conditions of the penalty clause were met, which
conditions are beyond the control of the selling shareholders. Accordingly,
there is no further investment decision on the part of the selling shareholders.

<PAGE>

Office of Corporate Finance
Securities and Exchange Commission
Attn: Mr. Max A. Webb and Mr. Daniel Morris
January 7, 2005
Page 6

The penalty clause was negotiated and determined prior to the filing of the
Registration Statement and was effective at the time of the closing of the
private placement. Moreover, the decision as to whether to make the penalty
payment in cash or stock is the Company's decision, not the selling
shareholders. Accordingly, there is no continuing investment decision on the
part of the selling shareholders. Moreover, shares may only be issued to the
selling shareholders at the discretion of the Company.

We submit that the issuance of the penalty consideration does not constitute an
investment decision on the part of the selling shareholders. We submit that the
filing of the Registration Statement does not defeat the private placement
exemption relied upon in connection with the October financing. In sum, the
Company submits that the private placement has closed, there is no continuing
offering of securities to the selling shareholders, and there is not a viable
argument that the delivery of any "penalty" shares, if issued, and the
underlying private placement which closed in October are somehow "integrated" as
a continuing or unified offering of securities. Accordingly, we do not think the
reliance on Regulation D as an exemption from the requirements of registration
under the 1933 Securities Act, as amended, is compromised or defeated.

Use of Proceeds, page 10

15.   Please add a second paragraph describing the uses of the proceeds of the
      Sept. 29th private placement.

In response to Staff's comments, corresponding changes have been made to the
Registration Statement.

Description of Our Business, page 11

16.   Much of the following account offers a generalized description of the
      government contracting business. Supplement it with a description of your
      business at the resent time of the registration statement. What are the
      current products? How many contracts are you currently competing for? How
      many do you typically compete for in a year? How many do you win? Since
      you only compete in multi-source contracts, do you have to interface with
      the other successful candidates?

In response to Staff's comments, corresponding changes have been made to the
Registration Statement.

<PAGE>

Office of Corporate Finance
Securities and Exchange Commission
Attn: Mr. Max A. Webb and Mr. Daniel Morris
January 7, 2005
Page 7

We supplementally note for Staff that the Company does not interface with any of
its competitors in the bidding process. In the context of the Company's
business, the Company does not confer with or interact with competitive bidders.
Rather, the Company only interacts with the government agency involved and/or
the Company's subcontractors required or selected on specific contracts.

While we have further expanded our discussion of our current business
activities, we do not believe that an exhausting, long and detailed listing of
parts produced would be useful to investors. Rather, we submit that describing
our bid status, coupled with the description of our business focus -as existing
and as modified in response to Staff comments - adequately sets forth an
understanding of our current and planned business model and operations.

Contracts for repair and overhaul, page 14

17.   You state that your average bid ranges from $150,000 to $2,000,000. We
      believe that this range is so wide that it is of limited usefulness to
      investors. In addition, please consider disclosing the specific dollar
      amount of your mean and median contract bids.

In response to Staff's comments, corresponding changes have been made to the
Registration Statement.

Project Management, page 14

18.   With a view toward disclosure, please supplem