Mail Stop 3561
								October 20, 2005

Mr. R.B. Harris, Chairman
Royal Holiday Mobile Home Estates, Inc.
419 Main Street #424
Huntington Beach, CA 92648

Re:	Royal Holiday Mobile Home Estates, Inc.
	Item 4.01 Form 8-K
	File No. 0-30261

Dear Mr. Harris:

      The staff has received a SECPS letter from Stonefield
Josephson
notifying the Chief Accountant of the Commission that the
registrant`s auditor/client relationship with Stonefield Josephson
has ceased.  This letter is to inform you that the registrant
should
file an Item 4 Form 8-K immediately.  The filing was due no later
than the fourth business day following the date the relationship
with
Stonefield Josephson ceased.

      Item 304 of Regulation S-B describes the disclosure
requirements of the Item 4 Form 8-K.  In order for the former
accountants to submit to you the letter required by Item 304(a)(3)
of
Regulation S-B, a copy of the filing should be furnished to them
as
soon as possible, but no later than the date you file the Form 8-K
with the Commission.  The accountant`s letter should be filed with
the Commission as an exhibit to the 8-K when initially filed or as
a
subsequent amendment thereto no later than 10 days after the
initial
Form 8-K was filed.

      If you are unable to file a Form 8-K and letter from the
former
accountant, please contact the staff immediately to explain your
extenuating circumstances. Direct any questions to Babette Cooper
at
202.551.3396.

							Sincerely,



							Babette Cooper
							Staff Accountant

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0306

         DIVISION OF
CORPORATION FINANCE