BOB STEPHENS & ASSOCIATES, P.C.
                            2825 Wilcrest, Suite 408
                              Houston, Texas 77042

                                                              Phone 713-339-3388
                                                                Fax 713-339-2355

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

Gentlemen:

We have read the  section  entitled  "Management's  Discussion  and  Analysis of
Financial Condition and Results of Operations -Change in Certifying  Accountant"
of  PalmWorks,  Inc.'s  registration  statement on Form S-1 and are in agreement
with the statements  contained in the three paragraphs of that section.  We have
no basis to agree or disagree with other statements of the registrant  contained
therein.


                                        Very truly yours,

                                        /s/ Bob Stephens & Associates, P.C.

Houston, Texas
June 20, 2000