SecProbe.io

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                          ELITE FLIGHT SOLUTIONS, INC.
                              710 Third Street, SW
                             Roanoke, Virginia 24061
                                 (703) 754-6409

April 22, 2005

VIA EDGAR AND FEDERAL EXPRESS

Ms. Linda Cyrkel, Branch Chief
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Mail Stop 0407
Washington, D.C. 20549

Re:      Elite Flight Solutions, Inc.
         Form 10-K for the year ended June 30, 2004
         File No.  1-31231

Dear Ms. Cyrkel:

         We are in receipt of your comment letter dated March 8, 2005. This
letter sets forth the responses of the Company to the comment letter. Your
comments are reproduced below:

Management's Discussion and Analysis
- Results of Operations

- Operating Expenses, page 10

COMMENT 1:                 Tell us supplementally and discuss in future filings
                           the component of other operating expenses in the
                           amount of $3,893,594 for the year ended June 30,
                           2004.

RESPONSE:                  Supplementally, the components of other operating
                           expenses for the year ended June 30, 2004 consisted
                           of $402,223 in aircraft insurance, $2,235,627 in
                           professional and consulting fees, $265,160 in rent
                           expense, $305,698 in travel and entertainment and the
                           remaining $684,886 represents miscellaneous general
                           and administrative expense. We will ensure that all
                           of our future filings discuss the components of other
                           operating expenses.

Financial Statements

Note 1 - Summary of Significant Accounting Policies

- Going Concern, page F-14

COMMENT 2:                 Tell us supplementally how your auditors determined
                           that the discussion provided represents a viable plan
                           that has the capacity of removing the threat to the
                           continuation of the business. The footnote does not
                           discuss funding arrangements and existing obligations
                           for the next twelve months. Revise in future filings
                           to provide a discussion of such viable plan. To the
                           extent management does not have such a plan, please
                           consult with your auditors as to the appropriateness
                           of the going concern opinion. Refer to guidance in
                           FRC 607.02 and SAS 34.

RESPONSE:                  Supplementally, our auditors determined that the
                           discussion provided represents a viable plan that has
                           the capacity of removing the threat to the
                           continuation of our business because the Company
                           continues to maintain the Equity Line of Credit with
                           Cornell Capital Partners, LP, which allows for access
                           to the additional sources of capital which appear to
                           provide sufficient funding. We will ensure that all
                           of our future filings provide a discussion of funding
                           arrangements and existing obligations for the next
                           twelve months.
<PAGE>

Ms. Linda Cykrel
United States Securities and Exchange Commission
April 22, 2004
Page 2

Principles of Consolidation, page F-14

COMMENT 3:                 Please revise in future filings to indicate the
                           name of the subsidiaries included in your accounts.
                           Currently, you refer to FlyJets.biz as your
                           consolidated subsidiary, however, based on your
                           discussion in the Organization section on page F-13,
                           it appears that FlyJets.biz changed its name to
                           Optimum and ceased operations. It appears that your
                           only consolidated subsidiary is America Air Networks
                           Alaska, Inc. Please make similar revisions to other
                           sections of your documentation as necessary.

RESPONSE:                  We will ensure that our future filings indicate the
                           name of the subsidiaries included in our accounts.
                           Supplementally, FlyJets.biz changed its name to
                           Optimum Aviation, Inc. in August 2004. Optimum
                           Aviation, Inc. has ceased its operations but is still
                           a subsidiary of Elite Flight Solutions, Inc. In
                           addition to Optimum Aviation, Inc., the Company
                           currently has two additional subsidiaries, America
                           Air Networks Alaska, Inc. and Delta Romeo, Inc.

Fixed Assets

COMMENT 4:                 Revise in future filings to disclose in the balance
                           sheet or footnotes the amount of assets recorded
                           under capital leases and the related accumulated
                           amortization. Also, the amortization charge shall be
                           separately disclosed in the statements of operations
                           or footnotes. Refer to the guidance in paragraph 13
                           of SFAS 13.

RESPONSE:                  In accordance with paragraph 13 of SFAS 13, our
                           future filings will disclose the amount of assets
                           recorded under capital leases and the related
                           accumulated amortization and we will ensure that the
                           amortization charges are separately disclosed in the
                           statements of operations or footnotes to the
                           financial statements.
<PAGE>

Ms. Linda Cykrel
United States Securities and Exchange Commission
April 22, 2004
Page 3

COMMENT 5:                 Revise in future filings to separately identify any
                           significant components of "other operating expenses"
                           on the face of the statements of operations or in the
                           related footnotes.

RESPONSE:                  We will ensure that our future filings separately
                           identify any significant components of other
                           operating expenses on the face of the statements of
                           operations or in the related footnotes. We identified
                           separate components for professional and consulting
                           fees, as well as aircraft insurance to the statement
                           of operations in the financial statements due to
                           their significance and due to the expectation that
                           these components will continue to be significant in
                           our future filings. Other components may be added as
                           deemed appropriate.

Note 6 - Convertible Debenture, page F-19

COMMENT 6:                 Tell us supplementally the members and their
                           respective interest of Cornell Capital Partners, LP.
                           Also, indicate to us if Cornell Capital Partners is
                           related to you in another manner other than as a debt
                           holder.

RESPONSE:                  Supplementally, all investment decisions of, and
                           control of, Cornell Capital Partners are held by its
                           general partner, Yorkville Advisors, LLC. Mark
                           Angelo, the managing member of Yorkville Advisors,
                           makes the investment decisions on behalf of and
                           controls Yorkville Advisors. Cornell Capital
                           Partners, LP is not related to the Company in no
                           other manner other than as a debt holder and an
                           investor under the Equity Line of Credit Agreement.
<PAGE>

Ms. Linda Cykrel
United States Securities and Exchange Commission
April 22, 2004
Page 4

Note 11 - Loss on Return of Aircraft, page F-21

COMMENT 7:                 Tell us supplementally how the loss on the return of
                           the Cessna Citation III aircraft of $887,473 was
                           calculated. In future filings, please classify such
                           amount within loss from continuing operations on your
                           statements of operations. Refer to paragraph 45 of
                           SFAS 144. Please revise your accounting policy for
                           recording gains and losses on fixed assets in
                           footnote 1 accordingly. We may have further comment
                           upon reviewing your response.

RESPONSE:                  Supplementally, the loss on the return of the Cessna
                           Citation III aircraft as stated in the statements of
                           operations and footnote 11 totaled $838,803, which
                           excludes depreciation of $48,670 and is based on the
                           following: (i) $700,000 in principal payments on the
                           related capital lease and (ii) $138,803 in fees and
                           penalties related to the repossession of the aircraft
                           as well as final settlements in negotiating a release
                           from the capital lease. In accordance with paragraph
                           45 of SFAS 144, our future filings will classify such
                           amounts within loss from continuing operations on our
                           statements of operations and our accounting policy
                           for recording gains and losses on fixed assets has
                           been revised accordingly.

Note 14 - Legal Proceedings, page F-22

COMMENT 8:                 We note that in March 2004 you entered into an
                           operating lease for a Cessna Citation III aircraft
                           with Thunder Aviation Acquisition, Inc. and
                           subsequently filed a lawsuit against you alleging
                           breach of the lease agreement in the amount of
                           $109,421.73, plus fees, costs and interest.
                           Supplementally tell us and clarify in future filings
                           what Thunder Aviation Acquisition, Inc. alleges in
                           their complaint and how the amount they are seeking
                           was determined. Also, tell us how you evaluated the
                           conditions of paragraph 8 of SFAS 5 in regards to the
                           outstanding litigation at June 30, 2004.

RESPONSE:                  Supplementally, Thunder Aviation Acquisition, Inc.
                           filed a lawsuit against EP Aviation, Inc. and the
                           Company alleging that EP Aviation, Inc. and the
                           Company breached its lease agreement by failing to
                           make the related lease payments and causing a lien to
                           be placed against the aircraft. Thunder Aviation
                           Acquisition, Inc. sought damages totaling $30,000 in
                           monthly base rent, $31,054 in landing expenses, and
                           $6,097 in other miscellaneous expenses. Further,
                           Thunder Aviation Acquisition, Inc. sought an
                           additional $47,271 to be incurred to release the
                           lien. The aircraft was subsequently returned and the
                           suit was settled in the amount of $50,000.
                           Accordingly, the Company recorded a loss related to
                           the $60,000 deposit and $30,000 in other prepaid
                           expenses for a total of $90,000. As of December 31,
                           2004, the Company recorded the settlement liability
                           as part of accounts payable, which was paid in
                           January 2005.
<PAGE>

Ms. Linda Cykrel
United States Securities and Exchange Commission
April 22, 2004
Page 5

                           Supplementally, the Company evaluated the conditions
                           of paragraph 8 of SFAS 5 in regard to the outstanding
                           litigation at June 30, 2004 and decided whether
                           losses from loss contingencies were to be accrued by
                           determining (i) if the information available prior to
                           the issuance of the financial statements indicated
                           that it is probable that a liability had been
                           incurred at June 30, 2004 and (ii) whether the loss
                           contingencies could be reasonably estimated.

Please call me or Clayton Parker at (305) 539-3306 if you have any questions.

Very truly yours,

Bruce Edwards
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