clickNsettle.com, Inc.
                                   990 Stewart Avenue, 1st Floor
                                   Garden City, NY 11530

July 14, 2005

Filed Via Edgar
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street, NE
Washington D.C. 20549

Attention: Mr. Matthew Maulbeck
           Staff Accountant
           Mail Stop 4561

RE:   clickNsettle.com, Inc.
      Form 8-K
      Filed 6/30/05
      File No. 0-21419

Dear Mr. Maulbeck:

This letter sets forth the responses of  clickNsettle.com,  Inc. (the "Company")
to the  comments  received  from  the  Staff  of  the  Securities  and  Exchange
Commission by letter dated July 8, 2005.

      Form 8-K filed June 30, 2005

      1.    Please  revise  the  Form to state  whether  the  former  accountant
            resigned,  declined to stand for  re-election or was dismissed,  and
            the specific  date, as required by Item  304(a)(1)(i)  of Regulation
            S-B. It is not sufficient to state that you and your former auditors
            "mutually  decided to terminate their  relationship" as that wording
            is unclear to a reader.

      Response to Comment 1:

We have filed an  amendment  to the Form 8-K whereby we provided  the  requested
information  as set forth  above.  Specifically,  the 4th  sentence of the first
paragraph under Item 4.01 of the Form 8-K/A states:



      As the Company no longer has an  operating  business,  Grant  Thornton LLP
("Grant  Thornton")  resigned as the  Company's  independent  registered  public
accounting firm on June 28, 2005.

The Company hereby acknowledges the following:

            o     the Company is  responsible  for the  adequacy and accuracy of
                  the disclosure in the Form 8-K/A filing;

            o     staff  comments or changes to disclosures in response to staff
                  comments  do not  foreclose  the  Commission  from  taking any
                  action with respect to the filing; and

            o     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.

If you have any  questions  or  comments  concerning  the  above,  please do not
hesitate to contact me at  516-941-3222.  My direct fax number is  516-213-7600.
Also,  please  update your records to use my direct fax number as the  Company's
fax going forward.

Very truly yours,


/s/ Patricia Giuliani-Rheaume
- -----------------------------
Patricia Giuliani-Rheaume
Vice President, Chief Financial Officer & Treasurer

cc: Robert S. Matlin, Thelen Reid & Priest LLP