Room 4561
						September 15, 2005

Bryan Abboud
Chief Executive Officer
Global Entertainment Holdings/Equities, Inc.
703 Waterford Way, Suite 690
Miami, FL 33126

Re:	Form 10-KSB for Fiscal Year Ended December 31, 2004
	Filed April 15, 2005
      From 10-KSB/A for Fiscal Year Ended December 31, 2004
	Filed September 2, 2005
      From 10-QSB for Fiscal Quarter Ended March 31, 2005
	Filed May 20, 2005
      From 10-QSB for Fiscal Quarter Ended June 30, 2005
	Filed August 22, 2005
	File No. 0-27637

Dear Mr. Abboud:

      We have reviewed the above referenced filings and have the
following comments.  Please note that 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 document.
We
may ask you to provide us with supplemental information so we may
better understand your disclosure.  Please be as detailed as
necessary in your explanation.  After reviewing this information,
we
may raise additional comments.

Form 10-KSB/A for the Fiscal Year Ended December 31, 2004

Note 1 - Summary of Significant Accounting Policies and General
Matters

Revenue Recognition, page F-10

1. With regards to your revenue recognition policy, please explain
the following:
* We note from your disclosures in Note 3 that revenue is
recognized
as the licensee has earned revenues through the use of your
software.
Please explain and also describe the terms of your license royalty
agreements.  Do these agreements have any minimum guarantee
provisions?  Also, identify all authoritative literature that you
have relied on in developing your revenue recognition policies.
* On page 14 of the June 30, 2005 Form 10-Q, you indicate that the
Company provides consulting, training and implementation services
as
well as ongoing customer support and maintenance.  Tell us how you
account for such services and tell us how you determined that the
Company does not have multiple element arrangements.
* We note that during fiscal 2004, one customer accounted for
approximately 90% of the Company`s total revenues and during the
six
months ended, June 30, 2005, this customer accounted for 100% of
your
revenues.  Tell us the name of this customer and tell us whether
there are any related party interests between the Company, its
officers and directors and this customer.

	As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
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 any amendment and 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
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 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.

      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 Kari Jin, Staff Accountant, at (202) 551-
3481
or me at (202) 551-3499 if you have questions regarding these
comments.

Sincerely,

      Kathleen Collins
      Accounting Branch Chief
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Mr. Bryan Abboud
Global Entertainment Holdings/Equities, Inc.
September 15, 2005
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