SecProbe.io

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      December 15, 2005

Mail Stop 4561

VIA U.S. MAIL AND FAX (507) 269-1473

Mr. Ronald Gorthuis
Chief Financial Officer
NK Aviation S.A.
PO Box 0819-09791
Panama, Republic of Panama

      Re:	Financial Telecom Limited (USA), Inc.
      Form 10-KSB for the year ended December 31, 2004
      Filed March 31, 2005
      File No. 000-50760

Dear Mr. Gorthuis:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  In our comments, we ask you to
provide
us with information so we may better understand your disclosure.
After reviewing this information, we may 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.

Form 10-KSB for the year ended December 31, 2004

Item 13. Exhibits, page 25

1. Please revise your certifications filed as Exhibits 31.1 and
31.2
to reflect the language exactly as set forth in Item 601(b)(31) of
Regulation S-B.  Please also make conforming revisions to your
subsequent Forms 10-QSB.

Form 10-QSB for the period ended September 30, 2005

Financial Statements and Notes

Note 5, Stockholders` Equity Transactions

(b) Stock Issuances, page 10

2. We note that you account for investments in companies in which
you
have less than a 20% ownership interest at cost.  Use of the cost
or
equity method of accounting should be based on the ability of an
investor to exercise significant influence over the operating and
financial policies of the investee.  Please tell us in sufficient
detail, and in future filings disclose as a significant accounting
policy, how you considered all means through which you might
influence the financial and operating policies of your investee
companies in determining the appropriate method of accounting.
Refer
to paragraph 17 of APB 18.  In your response, please also tell us
how
you considered each of the below factors in reaching this
conclusion:

a) Your ability, through contractual agreement, to designate one
of
the five directors on the Board of Directors for each of your
investee companies;

b) Substance of the difference between a 20% common stock
investment
and your 19% ownership interest after consideration of board
representation and your investment in debt securities of the
investee
which are convertible at issuance into additional equity interests
up
to 16%;

c) Significant intercompany transactions;

d) Any other voting rights, veto rights, and other protective and
participating rights.

3. If in response to comment 2 you determine that the equity
method
of accounting is more appropriate in the circumstance, please tell
us
whether any difference exists between the cost of each of your
investments and the underlying equity in net assets and how you
plan
to allocate such excess amount following the guidance in
paragraphs
35 - 47 of SFAS 141.

4. In future filings, please expand to include the disclosures
required by paragraph 20 of APB 18 and Item 310(b)(iii) of
Regulation
S-B, as applicable, including any purchase price adjustment
provisions and the impact of such provisions.

5. We note that you recorded the cost of your equity and debt
investments based on 50% of the average share price of your common
stock.  Please tell us your basis in accounting for recording the
cost of your investment at a price other than the fair value of
the
consideration issued.  Refer to paragraphs 20 - 23 and 29 of SFAS
141.

(c) Conditional Stock Options Granted to Independent Agents, page
10

6. Please advise us of, and expand your disclosure in future
filings
to include, your accounting policy with respect to stock options
granted to non-employees in exchange for services provided.
Specifically, tell us how you determine the measurement date and
whether sufficiently large disincentives exist for nonperformance.
In addition, tell us how you determine the cost and over what
period
you recognize the cost of services performed in your statement of
operations.  Refer to EITF 96-18.

Form 8-K filed on November 28, 2005

7. Please amend the filing to provide the information required by
Item 304(a)(1) of Regulation S-B under Item 4.01(a) of Form 8-K if
the registrant`s prior auditor has resigned, been dismissed, or
declined to stand for re-appointment as a result of the
acquisition.
In addition, please amend to file the financial statements and pro
forma financial information required by Item 310(c) and 310(d) of
Regulation S-B, respectively, under Item 9.01 of Form 8-K.  If the
financial statements are not yet available, please indicate when
such
statements will be filed in your amendment.

*  *  *  *

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

	You may contact Josh Forgione, at (202) 551-3431, or me, at
(202) 551-3403, if you have questions. Please respond to the
comments
included in this letter within ten business days or tell us when
you
will provide us with a response.  Please file your response on
EDGAR.

								Sincerely,

      Steven Jacobs
      Accounting Branch Chief

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Mr. Ronald Gorthuis
NK Aviation, S.A.
December 15, 2005
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