Jody M. Walker Attorney-At-Law 7841 South Garfield Way Centennial, CO 80122 Telephone: 303-850-7637 Facsimile: 303-220-9902 jmwalker85@earthlink.net October 8, 2004 Tracey Houser Securities and Exchange Commission 450 5th St. N.W. Washington, D.C. 20549 Re: Global Digital Solutions, Inc. File No. 0-26361 Form 8-K Item 4.01 filed October 4, 2004 Dear: Based on the comment letter dated July 12, 2004, please note the following responses. 1. The Form 8-K has been amended as requested. 2. References to Regulation S-K have been removed and replaced with the appropriate references to Item 304 of Regulation S-B. 3. Russell Bedford Stafanou Mirchandani LLP is auditing the Form 10-K for the year ended June 30, 2004. 4. The last sentence of Item 4(b) has been revised to comply with the disclosure requirements of Item 304(a)(2) of Regulation S-B. 5. An updated Exhibit 16 letter from the former accountants stating whether the accountant agrees with the statements made in the amended Form 8-K had been attached.