SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 4-7

March 8, 2005

Via U.S. Mail and Fax (801) 333-8589
Douglas W. Fry
President and Director
Autostrada Motors, Inc.
235 W. 500 South
Salt Lake City, Utah 84101

	RE:  	Autostrada Motors, Inc.
		Second Amendment to Form 10-SB
		Filed December 14, 2004
      File No. 0-51075

Dear Mr. Fry:

	We have reviewed the above filing and have the following
comments.  Where indicated, we think that you should revise your
Form
10-SB 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 supplemental information so that we may better understand
your
disclosure.  After reviewing this information, we may or may not
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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. You still refer to your company as a "blank check company"
under
the risk factor captioned, "Effect of Existing or Probable
Governmental Regulations on Business."  Please revise to remove
the
use of that term in your Form 10-SB.

Item 2. Managements` Discussion and Analysis or Plan of Operation

	Liquidity

2. We reissue part of our prior comment 12.  We note your
discussion
of your triple net one year lease under your "Business"
description;
however, you should expand to explain your obligation to pay for
all
repairs, maintenance, and taxes associated with the property and
buildings for the term of the lease.  In addition, please file
your
"triple net one year lease" as an exhibit to your Form 10.

Item 6. Employment Contracts and Termination of Employment and
Change-in-Control Arrangements

3. We reissue part of our prior comment 19.  Please revise to
discuss
the potential conflicts of interest in having the employment
agreements executed on behalf of the company and management by the
same individuals.

Item 7. Certain Relationships and Related Transactions

4. We note that Stephen and Douglas Fry were not identified as
owners
of Diamond in the Business section when discussing the terms of
the
company`s triple net one year lease.  Please revise the discussion
to
make clear that they own Diamond.

Part II-Item 1. Market Information

5. We reissue part of our prior comment 21.  Please revise to
correct
the incorrect statement that the company intends to submit for
quotation of its common stock on the OTC Bulletin Board.  Only
brokers may apply to the NASD to quote a company`s securities on
the
Bulletin Board.  Revise the market references throughout your Form
10
to clarify that only brokers who agree to be market makers in a
company`s stock can file with the NASD to have an issuer`s
securities
quoted on the OTC Bulletin Board.  Also clarify whether the
company
has approached any brokers to do so.

Financial Statements for the period ended December 31, 2003

Note 1-Organization and Summary of Significant Accounting Policies

6. We reissue prior comment 22.  Tell us in more detail how you
determine the market value of your inventory.  More specifically,
tell us why you believe book value approximates market value.

Financial Statements for the period ended September 30, 2004

General

7. We are reissuing our prior comment 23.  Please include the
footnotes to the September 30, 2004 financial statements as
required
by rule Regulation S-B.T.Item310 paragraph (b).  In this regard,
revise to include footnote disclosure regarding your leasehold
improvements and consulting agreement.

8. We are reissuing our prior comment 24.  Supplementally provide
us
with more details of the nature of your consulting agreement, your
accounting for it, and your basis in the accounting literature.

9. We are reissuing our prior comment 25.  We note that your
condensed balance sheet at September 30, 2004 identifies you as a
"development stage company."

* Tell us how you determined that you were in the development
stage
considering that you had revenues of $696,662 during the nine
months
ended September 30, 2004.

* Also, tell us why your financial statements for the period ended
December 31, 2003 do not reference the fact that you are a
"development stage company."

*	*	*	*

      As appropriate, please respond to our comments within 10
business days, or tell us when you will provide us with a
response.
Please furnish a cover letter on EDGAR that keys your responses to
our comments and provides us with any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Understand that we may have additional comments after reviewing
your
responses to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging 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 in the filing reviewed by the staff 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.

   In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Michael Henderson, Staff Accountant, at (202)
824-5551, or Kyle Moffatt, Accountant Branch Chief, at (202) 942-
1829, if you have questions regarding comments on the financial
statements and related matters.  Please contact Derek Swanson,
Staff
Attorney, at (202) 824-5526, or me at (202) 942-1990 with any
other
questions.

							Sincerely,

							Larry Spirgel
							Assistant Director

??

??

??

??

Autostrada Motors, Inc.
March 8, 2005
Page 1 of 4

</TEXT>
</DOCUMENT>