SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
						April 12, 2005

Mail Stop 05-11

Scott D. Olson
PivX Solutions, Inc.
23 Corporate Plaza
Suite 280
Newport Beach, CA 92660

Re:	Form 8-K filed April 7, 2005
	File No. 0-33625

Dear Mr. Olson:

	We have reviewed your filing and have the following comments.
The review was limited to the Item 304 disclosures and additional
comments may follow at a later time concerning the financial
statements.  Where indicated, we think you should revise your
document in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  In some of our comments, we may ask you
to
provide us with supplemental information so we may better
understand
your disclosure.  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 any other aspect
of
our review.  Feel free to call the applicable staff person at the
telephone number listed at the end of this letter.

Exhibit 16 Letter:

      The letter filed by the former accountants references a Form
8-
K dated March 6, 2005.  The relevant Form 8-K filed on April 7,
2005
was dated April 3, 2005.  Please file a letter from your former
accountant stating whether the accountant agrees with your Item
304
disclosures, or the extent to which the accountant does not agree
with the proper date reference for the Form 8-K.

      Please file your supplemental response and amendment via
EDGAR
in response to these comments within 5 business days after the
date
of this letter.  Please contact the staff immediately if you
require
longer than 5 business days to respond.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the registrant and its management are
in
possession of all facts relating to a registrant`s disclosure,
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 registrant acknowledging that:
* the registrant is responsible for the adequacy and accuracy of
the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the registrant 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 filing or in
response to our comments on your filing.

      Direct any questions regarding this letter to Babette Cooper
at
202-824-5069.

						Sincerely,

						Babette Cooper
						Staff Accountant
??

??

??

??

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0306

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>