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  staff  comments  and  the   declaration  of
     effectiveness 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