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.