October 21, 2005

VIA EDGAR

United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549

         Re:      eTotalSource, Inc.
                  Registration Statement on Form SB-2
                  Filed on April 21, 2005
                  File No. 333-124220

Ladies and Gentlemen:

         Pursuant to Rule 477(a) under the General Rules and Regulations under
the Securities Act of 1933, as amended (the "Securities Act"), please consider
this correspondence as an application to the United States Securities and
Exchange Commission (the "Commission") for an order permitting eTotalSource,
Inc. (the "Registrant") to withdraw the Registration Statement on Form SB-2
filed by the Registrant on April 21, 2005. No securities were sold in connection
with the Registration Statement.

         The Registrant further requests that all fees paid to the Commission in
connection with the filing of the Registration Statement be credited for future
use in accordance with Rule 457(p) of the Securities Act.

         Accordingly, the Registrant hereby respectfully requests that, in
accordance with the provisions of Rule 477(a) under the Securities Act, an Order
granting the withdrawal of the Registration Statement be issued by the
Commission as soon as practicable.

         If you have any questions or comments regarding the foregoing
application for withdrawal, please contact Clayton E. Parker, Esq., or
Christopher J. DeLise, Esq., legal counsel to the Registrant, at 305-539-3300.
Please provide a copy of the Order consenting to this withdrawal to Messrs.
Parker and DeLise by facsimile at 305-358-7095. Thank you for your assistance.

                                     Sincerely,

                                     /s/ Terry L. Eilers
                                     ---------------------------------------
                                     Terry L. Eilers,
                                     Chief Executive Officer, Chairman, and
                                     Principal Executive Officer