Mail Stop 6010 						March 10, 2006 Mr. Lowell W. Giffhorn Chief Financial Officer Omni U.S.A., Inc. 2236 Rutherford Road, Suite 107 Carlsbad, CA 92008 Re:	Omni U.S.A., Inc. Form 10-KSB for the year ended June 30, 2005 Filed October 13, 2005 File No. 0-17493 Dear. Mr. Giffhorn: 	We have completed our review of your Form 10-KSB and related filings and do not, at this time, have any further comments. 						Sincerely, 						Martin F. James 						Senior Assistant Chief Accountant