SecProbe.io

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Mail Stop 6010

								November 28, 2005

Robert L. Cashman
Director, President, and Chief Executive Officer
Smart Truck Systems, Inc.
22101 Alessandro Blvd.
Moreno Valley, CA. 92553

	Re:	Smart Truck Systems, Inc.
		Registration Statement on Form SB-2
		Amendment no. 1 filed November 9, 2005
		File No. 333-128107

Dear Mr. Cashman:

	We have reviewed your filing and have the following comments.
Where indicated, we think you should revise your document 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 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 any other aspect of
our
review.  Feel free to call us at the telephone numbers listed at
the
end of this letter.

FORM SB-2

Prospectus Cover Page

1. We note the revisions pursuant to comment 3.  Please disclose
the
information required by Item 501(a)(9)(iii) of Regulation S-B.

Prospectus Summary, page 3

2. We note your response to comment 7, and we reissue the comment
in
part.  Please disclose when "[m]anagement plans to augment its
growth
strategy by increasing marketing efforts to securing additional
long-
term contracts with major chassis manufactures and additional
volume
at its existing operations."  Also, disclose the principal
obstacles
the company will need to overcome to do so.

Investors in our common stock will pay a price . . . , page 5

3. We note the revisions pursuant to comment 8.  We did not intend
to
suggest you should revise the risk factor to include only the
disclosure requested by the comment.  Please put the disclosure
regarding the net tangible book value, shares outstanding, and
dilution percentage back into the risk factor.

We are subject to government regulation . . . , page 9

4. We note you expanded "Anti-pollution regulations may affect . .
."
on page 6 in response to comment 12 to discuss certain anti-
pollution
regulations.  You also state that none of the anti-pollution
regulations are materially burdensome.  Please similarly expand
this
risk factor to discuss any regulations other than anti-pollution
regulations that have been particularly burdensome.

Management`s Discussion and Analysis of Financial Conditions and
Results of Operations for the Year Ended June 30, 2005, page 15

5. We note your response to comment number 25 and your revised
disclosure.  Please describe your other critical accounting
estimates
in addition to your asset acquisition valuation estimates.
Critical
accounting estimates arise when significant estimates are made
when
applying your accounting principles.  The critical accounting
estimate
disclosure should provide greater insight into the quality and
variability of the information regarding financial condition and
operating performance.  The discussion should present your
company`s
analysis of the uncertainties involved in applying a principle at
a
given time or the variability that is reasonably likely to result
from
the principle`s application over time.  The disclosure should
address
specifically why the accounting estimate or assumptions bear the
risk
of change.  Please refer to FRR-72.

Description of the Business, page 17

6. We note your response to comment 1.  Please file the agreement
with
HT&T Hawaii LLC as an exhibit to your registration statement, and
discuss its terms in your Business section.  It also appears you
should file your agreement with the City of Fresno and discuss its
material terms in your Business section.

7. We note your response to comment 30.  Please disclose the
monthly
rent you pay for the manufacturing facility.

8. We note the revisions pursuant to comment 32.  We note the
manufacturing, research and development assets Kosti Shirvanian
received in the sale of Western Waste to U.S.A. Waste Services
"were
part of the total consideration of approximately 1 billion dollars
paid by U.S.A. Waste Services, Inc." and that "[n]o specific
dollar
amounts were allocated to these assets."

* Please explain what these assets consisted of and how much Mr.
Shirvanian originally paid for them.
* Please disclose the form and amount of other consideration given
to
Mr. Shirvanian in the transaction with U.S.A. Waste Services.
* Please explain which assets Mr. Shirvanian contributed to Smart
Truck Systems on September 1, 2004 and which ones he retained.

9. We note your response to comment 37, and we reissue the
comment.
In the second paragraph on page 20, you make claims about your
trucks`
efficiencies, economy, and minimal maintenance.  Please provide
support for these claims either by citing a third-party study that
supports them or by comparing your trucks` efficiencies, economy,
and
maintenance to industry averages.

Family Relationships, Certain Relationships and Related
Transactions,
page 28

10. Please disclose when the sales to Pacific Waste, Aloha Waste,
and
Waste Resources took place.

Report of Independent Registered Public Accounting Firm, page F-2

11. We note your revision to the auditor`s report to define the
periods for which the audit report covers the statements of
income,
changes in stockholder`s equity and cash flows.  It appears that
the
first and forth paragraph of the auditor`s report should reference
the
period from June 11, 2004 through June 30, 2004 not June 20, 2005.
In
addition, the year of the inception to date period in the last
paragraph should read June 30, 2005 not June 30, 200.  Please
revise
the auditor`s report accordingly.

12. In accordance with AU Section 508.07, please revise the forth
paragraph of your auditor`s report to reference U.S generally
accepted
accounting principles instead of generally accepted accounting
standards.

13. We note your response to comment number 45.  In accordance
with AU
Section 341.12, the auditor`s conclusion about the entity`s
ability to
continue as a going concern should be expressed through the use of
the
phrase "substantial doubt about its (the entity`s) ability to
continue
as a going concern."  In addition, footnote 5 located in paragraph
.13
restricts the use of conditional language within in the auditor`s
opinion in expressing a conclusion concerning the existence of
substantial doubt about the entity`s ability to continue as a
going
concern.  Please revise your auditor`s opinion accordingly.

Consolidated Financial Statements

14. We note your response to comment number 46 and the expanded
disclosure related to your revenue recognition policy.  Please
expand
your disclosure to address the other criteria of revenue
recognition
listed in SAB Topic 13.A.1 that must be met prior to revenue
recognition.  In addition, please revise your disclosure to
address
each revenue stream discussed under "General" on page 16.  We note
that you sell truck bodies and parts and you make repairs.
Discuss
any items that reduce gross revenue such as cash rebates, returns,
and
any other discounts or allowances.

History, page F-7

15. We note your response to comment number 48.  Please address
the
following comments:

* Cite the accounting literature you followed when recognizing the
goodwill in connection with the purchase of the voting control of
Homesmart.com.
* Disclose the $250,000 payment made for the voting control.
* Clarify what voting control means and why it didn`t include an
acquisition of voting stock.
* Clarify to us why you believe no shares were exchanged.  It
appears
based on the disclosure in "History" on pages 17 and 18 that you
acquired 27,000,000 shares of Homesmart, which were canceled after
the
merger.  In addition, your Stockholders` Equity section implies
that
you issued 494, 951 shares of your stock in the merger.
* Clarify in the filing who the accounting acquirer was in the
transaction and whose financial statements are presented in the
filing.  Tell us your basis for determining who the accounting
acquirer was.

Development Stage, page F-10

16. We note your response to comment number 49.  It appears that
neither condition a nor b in paragraph 8 of SFAS 7 exists which
would
allow you to identify yourself as a development stage enterprise.
It
appears that you have commenced your planned principal operations
of
manufacturing trash collection trucks and that you have earned
significant revenue from your operations.  Please revise your
filing
accordingly or explain to us why you do not believe a revision is
necessary under GAAP.

Note 2 - Asset Purchase Agreement, page F-10

17. We note your response to comment number 50.  Please note that
according to paragraph 4 part e of APB 29, the statement does not
apply to a transfer of assets to an entity in exchange for an
equity
interest in that entity.  It appears that the transfer was from a
promoter of the company and should be recorded at historical GAAP
basis.  Refer to Staff Accounting Bulletin 5:G.

Item 27. Index to Exhibits, page II-3

18. Exhibits filed pursuant to Item 601(b)(10) of Regulation S-B,
such
as the employment agreement and the lease agreement, should be
numbered 10.1, 10.2, 10.3, etc.  Please revise.

*	*	*

	As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

	You may contact Dana Hartz at (202) 551-3648 or Mary Mast at
(202) 551-3613 if you have questions regarding comments on the
financial statements and related matters.  Please contact Greg
Belliston at (202) 551-3861 or me at (202) 551-3715 with any other
questions.

								Sincerely,

								Jeffrey Riedler
								Assistant Director

cc:	Dennis Brovarone
	Attorney and Counselor at Law
	18 Mountain Laurel Drive
	Littleton, Colorado 80127
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Robert L. Cashman
Smart Truck Systems, Inc.
November 28, 2005
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