SecProbe.io

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                   CREDIT ONE FINANCIAL, INC
                  505 E.New York Ave., Suite 8
                        DeLand, FL 32724
                386-943-8446 * Fax 386-736-1061

November 21, 2005

Paula Smith, Staff Accountant
Securities and Exchange Commission
Washington, D.C. 20549   Mail Stop 4561

          Re: Credit One Financial, Inc.
              Form 8-K filed November 3, 2005
              File No. 0-50320

Dear Ms. Smith:

   We have received your comment letter dated November 18, 2005.
We have reviewed all of your comments and spoken to you by
telephone regarding some of our intended responses to some of
your comments and sought guidance on other comments. The
responses that follow are numbered to correspond with the numbers
of your comments. They are also inserted, where applicable, into
the amended Form 8-K document.

   Our responses to your comments are as follows:

1.  There were no adverse opinions or disclaimers of opinion or
modifications as to uncertainty, audit scope or accounting
principals from the predecessor auditor, Robert N Clemons, CPA,
PA.

2.  There were never any disagreements with the predecessor
auditor on any matter of accounting principals or practices,
financial statement disclosure or auditing scope or procedure.

3. The Registrant's predecessor auditor, Robert N Clemons, CPA,
PA,a sole practitioner, died suddenly and unexpectedly of a heart
attack at his home on September 23, 2005.

The Registrant is unable to procure a letter from Mr. Clemons as
required by Item 304(a)(3) of Regulation S-B because he is dead.

The Registrant was unable to disclose to the predecessor any
disagreements with him because it had no disagreements with him
and he is dead.

In connection with responding to your comments the Company
understands that:

     The company 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 company 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

We wish to thank you for your guidance in our responding to some
of your comments.

Sincerely,

s/James H Bashaw
James H Bashaw, President

ENCL.:

C:\Documents and Settings\Owner\My Documents\Credit One sec\secsmith.1121.wpd

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