SecProbe.io

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<TYPE>CORRESP
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                         DAVID M. LOEV, ATTORNEY AT LAW
                         2777 ALLEN PARKWAY, SUITE 1000
                               HOUSTON, TX  77019
                            TELEPHONE (713) 524-4110
                             FACSIMILE (713) 524-4122

                                October 11, 2005

Ms. Yolanda Crittendon                          VIA FAX AT (202) 772-9209
Staff Accountant                                -------------------------
Division of Corporate Finance
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Phone: (201) 772-9209

RE:  National  Parking  Systems,  Inc.
     Form  10-KSB  for  the  year  ended  December  31,  2004
     Form  10-QSB  for  the  quarters  ended  March  31,  2005 and June 30, 2005
     File  No.  000-49933

Dear  Ms.  Crittendon:

     In  response  to  your  letter  dated  September  7, 2005, National Parking
Systems,  Inc.  (the  "Company")  has  the  following  responses:

FORM  10-KSB
------------

ITEM  1  -  DESCRIPTION  OF  BUSINESS,  PAGES  3  -  10
-------------------------------------------------------

BUSINESS  DEVELOPMENT,  PAGES  3-5
----------------------------------

1) The $200,000 in notes payable was with the Company's wholly owned subsidiary,
Cascade  Mountain  Mining  Corp.  ("Cascade")  and  was  assigned to Cascade and
Cascade's  Chief  Executive  Officer  (who  is  also  the Company's former Chief
Executive Officer) pursuant to a General Release and Settlement Agreement, filed
as  Exhibit  10.14  to  the  Company's 10-KSB. Cascade was spun off prior to the
Stock  Exchange Agreement with BH Holding Company, Inc. and ABS Holding Company,
Inc.  Therefore,  the  Company  believes it had no responsibility for such debt.
Please  refer  to  "Note H Commitments and Contingencies-Other" of the Company's
audited  10-KSB  financials  and  "Note  D Commitments and Contingencies" of the
Company's Quarterly Report on Form 10-QSB for the quarter ended June 30, 2005.

     With respect to the $201,930 of shareholder loans, such loans were released
by the shareholders pursuant to  the General Release  and  Settlement  Agreement

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prior  to  the  Stock  Exchange  Agreement.  Accordingly,  such  debt  which was
forgiven  was taken into income prior to the Stock Exchange Agreement and change
of  control.

ITEM  6  -  MANAGEMENT'S  DISCUSSION  AND  ANALYSIS  OR  PLAN  OF  OPERATION
----------------------------------------------------------------------------

COMPARISON  OF  OPERATING  REVENUE,  PAGES  13-14
-------------------------------------------------

FISCAL  YEAR  ENDED DECEMBER 31, 2004 COMPARED TO FISCAL YEAR ENDED DECEMBER 31,
--------------------------------------------------------------------------------
2003,  PAGE  13
---------------

2) By "changes in the Company's accounting practice" the Company meant only that
it  had  put stricter controls and procedures in place with respect to the money
which  its  employees  received.  There  was  no  actual change in the Company's
"accounting  practices"  which  would  require  GAAP  support  or otherwise. The
Company  plans  to  file  an  amended  10-KSB  which will revise and clarify the
Company's statement regarding "changes in [its] accounting practices" subsequent
to the filing of this response letter.

ITEM  7-FINANCIAL  STATEMENTS
-----------------------------

CONSOLIDATED  STATEMENTS  OF  STOCKHOLDERS'  DEFICIT,  PAGE  F-5
----------------------------------------------------------------

3)  National  Parking  Systems,  Inc.  is  the  private  operating  company. The
Consolidated  Statement  of  Stockholders'  Deficit on page F-5 of the Company's
audited  financial  statements  shows  the  historical  deficit  of  the private
operating  company,  which  is  $66,812. This deficit includes $1,559 of deficit
from  the public company which could not be capitalized and which was deemed not
to be significant.

NOTE  A-SUMMARY  OF  SIGNIFICANT  ACCOUNTING  POLICIES,  PAGES  F-6  TO  F-8
----------------------------------------------------------------------------

GENERAL
-------

4)  The Company recognizes revenue for the valet and parking establishments when
the  service  is  performed.  Cash is collected immediately and deposited in the
bank  the  next day with proper reconciliation and accountability. In connection
with the booting services, revenue is recognized when the service is performed.

REVERSE  MERGER,  PAGE  F-6
---------------------------

5)  The  Company  believes  that  both  ABS Holding Company, Inc. and BH Holding
Company,  Inc.  were  under  common control at the time of their acquisition, as
each was controlled by Marc Ebersole, who also serves as Chief Executive Officer
of  the Company, and consequently, they were treated as the Accounting Acquirers
within the reverse acquisition.

NOTE  C-COVENANT  -NOT  -TO  COMPETE,  PAGE  F-9
------------------------------------------------

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6)  There  were no cash payments recorded for the Intangible Assets-Covenant not
to  compete.  The Covenant was offset by notes payable. The footnote incorrectly
included  a series of cash payments in error and the Company plans to revise the
footnote  in  its  amended Report on Form 10-KSB filing to be made subsequent to
the filing of this response letter.

ITEMS  8A  -  CONTROLS  AND  PROCEDURES,  PAGE  20
--------------------------------------------------

7)  The  Company's  Chief  Executive  Officer  and  Chief  Financial Officer did
conclude  that  the Company's disclosure controls and procedures were effective,
and  the  Company  plans  to revise Item 8A in its amended Report on Form 10-KSB
filing  to  be  made subsequent to the filing of this response letter to clarify
that its controls and procedures were effective.

FORM  10-QSB  FOR  THE  PERIOD  ENDING  JUNE  30,  2005
-------------------------------------------------------

ITEM  1-  FINANCIAL  STATEMENTS
-------------------------------

NOTE  B-PURCHASE  OF  PRO-SYSTEMS  PARKING
------------------------------------------

8) The acquisition of Pro-Systems Parking was the purchase of fixed assets and a
customer  listing. The total purchase price was $10,000. The Company paid $5,000
down and the balance in installment payments. There was no entity acquired.

ITEM  3  -  CONTROLS  AND  PROCEDURES
-------------------------------------

9)  The  Company's Chief Executive Officer and Chief Financial Officer concluded
that  the  Companys disclosure controls and procedures were effective as of June
30, 2005, and it was incorrectly stated in the Companys Quarterly Report on Form
10-QSB  for the period ended June 30, 2005, that he concluded that such controls
and  procedures  were  ineffective.  The  Company  plans  to revise Item 3 in an
amended  Report  on  Form  10-QSB for the quarter ended June 30, 2005, which the
Company plans to file subsequent to the filing of this response letter, to state
that its controls and procedures were effective as of June 30, 2005.

                         Yours  Very  Truly,

                         /s/ John S. Gillies
                         -------------------------------------------
                         John S. Gillies, Associate
                         David  M.  Loev,  Attorney  at  Law

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