AMERICAN AMMUNITION, INC.
                               3545 NW 71st Street
                              Miami, Florida 33147



                                                June 2, 2005



VIA FACSIMILE AND EDGAR

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

Attention:  Matt Franker



         Re:      American Ammunition, Inc.
                  Registration Statement on Form SB-2
                  File No. 333-122056


Ladies and Gentlemen:

     Pursuant  to Rule  461 of the  General  Rules  and  Regulations  under  the
Securities Act of 1933, as amended (the "Act"),  American Ammunition,  Inc. (the
"Company")  respectfully  requests that the effective  date of the  registration
statement  referred to above be accelerated so that it will become  effective at
4:30 p.m.,  Eastern  Time,  on Friday  June 3, 2005,  or as soon  thereafter  as
possible.

     We hereby acknowledge the following:

     o    that should the Commission or the staff,  acting pursuant to delegated
          authority,  declare the filing  effective,  it does not  foreclose the
          Commission from taking any action with respect to the filing;

     o    the  action  of  the  Commission  or the  staff,  acting  pursuant  to
          delegated  authority,  in  declaring  the filing  effective,  does not
          relieve the Company from its full  responsibility for the adequacy and
          accuracy of the disclosure in the filing; and

     o    the Company may not assert this action as a defense in any  proceeding
          initiated by the Commission or any person under the federal securities
          laws of the United States.






                                                AMERICAN AMMUNITION, INC.


                                                By: /s/ Andres Fernandez
                                                Name: Andres Fernandez
                                                Title: Chief Executive Officer