SecProbe.io

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<TYPE>LETTER
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<FILENAME>filename1.txt
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Mail Stop 3561
								June 14, 2005

Vance Ito, Principal Financial Officer
Pivx Solutions, Inc.
23 Corporate Plaza, Suite 280
Newport Beach, CA 92660

Re:	Pivx Solutions, Inc.
	Item 4.02 Form 8-K
      Filed June 2, 2005
      Supplemental response letter
      Filed June 13, 2005
	File No.  0-33265

Dear Mr. Ito:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your documents 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.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with more
information so we may better understand your disclosure.  After
reviewing this information, we may 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 us at the telephone numbers listed
at
the end of this letter.

      While your supplemental response to our previous comment 2
states the auditor did not examine or review any records,
transactions, or events after March 15, 2005, the financial
statements were revised on June 7, 2005 to record a decrease of
$1.9
million in total assets and additional paid in capital and to
provide
additional disclosure in Note 2.  Please note that AU 530
specifically states that if a subsequent event occurs after the
date
of the auditor`s report and the financial statements are adjusted
and
disclosure of the event is made, then the auditor must date the
report as set forth in paragraph .05 of AU 530.  Please have the
auditors revise their report accordingly.

	 We note that you filed the Form 8-K/A Amendment #1 as
correspondence in EDGAR.  Please file the amended Form 8-K/A
Amendment #1 in public EDGAR.

       As appropriate, please amend your filing and respond to
these
comments within five business days or tell us when you will
provide
us with a response.  You may wish to provide us with marked copies
of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	If you have any questions, please call Babette Cooper at
(202)
551-3396

							Sincerely,

							Babette Cooper
							Staff Accountant

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

         DIVISION OF
CORPORATION FINANCE

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