MOMENTUM BIOFUELS, INC.


                                  June 24, 2011




Securities and Exchange Commission
Attention: John Cash
100 F St. NE
Washington, D.C. 20549

Re:      Momentum BioFuels, Inc.
         Form 10-K for the year ended  December  31,  2010 Filed  April 15, 2011
         File No. 0-50619

Dear Mr. Cash:

In response to your letter dated June 15, 2011  regarding  the Annual  Report on
Form 10-K for the year ended  December  31, 2010 of Momentum  BioFuels,  Inc. we
acknowledges to the SEC that

1.   The Company is responsible  for the adequacy and accuracy of the disclosure
     in their filings;

2.   Staff  comments or changes to disclosure  in response to staff  comments do
     not  foreclose  the  Commission  from taking any action with respect to the
     filing; and

3.   The Company may not assert  staff  comments as a defense in any  proceeding
     initiated by the Commission or any person under the federal securities laws
     of the United States.

We believe this satisfies your requirement.

                                          Sincerely,

                                          MOMENTUM BIOFUELS, INC.



                                         /s/George Sharp
                                            ------------
                                            Chief Executive Officer