SecProbe.io

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                       SICHENZIA ROSS FRIEDMAN FERENCE LLP
                  1065 AVENUE OF THE AMERICAS NEW YORK NY 10018

                TEL 212 930 9700 FAX 212 930 9725 WWW.SRFFLLP.COM

                                                              October 18, 2004

VIA FACSIMILE (202) 942-9544

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC  20549

         Attn:    Barbara Jacobs, Assistant Director
                  Tangela Richter, Esq.

         Re:      Cintel Corp.
                  Registration Statement on Form SB-2
                  File No. 333-119002

Ladies and Gentlemen:

         The following  responses address the comments of the reviewing Staff of
the  Commission as set forth in a comment letter dated October 13, 2004 relating
to the Registration  Statement on Form SB-2 of Cintel Corp. (the "Company").  On
behalf of the Company, we respond as follows.

STANDBY EQUITY DISTRIBUTION AGREEMENT, PAGE 10

1.       We do not  understand  certain  provisions of the agreement  that would
         terminate Cornell Capital  Partners'  obligation to make advances under
         certain  circumstances.  For  example,  we note  that  Cornell  Capital
         Partners'  obligation  is  terminated  if you  fail  to  comply  with a
         provision  restricting  you from  issuing or selling any  contracts  or
         securities  granting  the holder  the right to  acquire  shares of your
         common stock without  consideration or for  consideration  that is less
         than  the bid  price  of the  common  stock  immediately  prior  to the
         issuance.  Describe  with  specificity  the  purpose and effect of this
         provision.  How is this  provision  consistent  with Rule  10a-1 of the
         Securities  Exchange  Act of 1934?  Likewise,  what is the  purpose and
         effect of the  provision  restricting  you from  filing a  registration
         statement  on Form S-8 to  register  and issue in excess of two million
         shares?  We note that the  provision  also  requires  that you  provide
         notice to Cornell  Capital  Partners prior to the  registration on Form
         S-8 of the issuance of two million or fewer shares.

         RESPONSE

         We note the  provisions  you  reference  in Section  6.8 of the Cornell
         Agreement,  relating to  restrictions  on sale of capital stock.  These
         covenants  are intended to prevent  excessive  numbers of  free-trading
         shares from  reaching the market at a time when Cornell is obligated to
         make significant purchases of stock from the Company. If the provisions

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         were  not in  place,  large  sales  of new  securities  could  have  an
         unanticipated  depressive  effect on the market price of the  Company's
         common  stock,  making  it more  difficult  for  Cornell  to  sell  the
         securities it purchases  from the Company.  It is a customary  covenant
         which many funding source  require  issuers to undertake at the time of
         financing  transactions.  We do not believe these provisions are in any
         way inconsistent with Rule 10a-1.

2.       We note your  disclosure  throughout  the  registration  statement that
         Cornell  Capital  Partners  will receive a two percent  discount to the
         market  price  of  your  common  stock.  However,  we  note  also  your
         disclosure that you have agreed to pay them 5% of the proceeds that you
         receive   under   the   Equity   Distribution   Agreement.   Under  the
         circumstances,  it appears that your  disclosure in Risk Factors and in
         the  table  on  page  10  that  refers  only  to  the  2%  discount  is
         inappropriate. Please revise throughout to clarify that Cornell Capital
         Partners will receive,  in effect, a 7% discount to the market value of
         your common stock.

         RESPONSE

         Under  the  Standby  Equity  Distribution  Agreement,  Cornell  Capital
         Partners  will pay 98% of the  lowest  closing  bid price of the common
         stock during the five consecutive trading days immediately  following a
         notice date. Upon each advance,  Cornell Capital  Partners will be paid
         5% of the gross  proceeds of the advance in cash.  This is in effect 5%
         cash fee equal to 98% of the defined  price.  The two percent  discount
         affects  the  number of shares  to be issued to  Cornell,  not any cash
         payment to be made.  Changing the  discount to 7% would not  accurately
         reflect the discount  which Cornell  receives  upon each  advance.  The
         prospectus  currently  discloses  the 5% cash  payment  following  each
         disclosure of the price that Cornell Capital  Partners will pay for our
         common stock. Accordingly, we do not believe that the prospectus should
         be revised.

         We trust that the foregoing  appropriately  addresses the issues raised
by your recent comment  letter.  Thank you in advance for your prompt review and
assistance.

                                             Very truly yours,

                                             /s/ David Schubauer
                                             -------------------
                                             David Schubauer

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