FREESTAR TECHNOLOGY CORPORATION
                               CALLE FANTINO FALCO
                               J.A. BAEZ BUILDING
                                    2ND FLOOR
                        SANTO DOMINGO, DOMINICAN REPUBLIC
                                  (809)368-2001


                                                               December 12, 2005

VIA EDGAR  AND FAX

Ms. Tamara Tangen, CPA
Division of Corporate Finance
U.S. Securities & Exchange Commission
Washington, D.C. 20549


Re: FreeStar Technology Corporation
       File No. 0-28749
       Form 10-KSB for June 30, 2004
       Form 10-KSB/A for June 30, 2004
       Form 10-QSB for the quarters ended September 30, 2004,
       December 31, 2004 and March 31, 2005


Dear Ms. Tangen:

         I would like to apologize  for our failure to respond to your letter of
July 19,  2005.  I  understand  that in the last  conversation  you had with the
Company, we agreed to provide a complete response 21 days from the date we filed
our Form  10-KSB.  This form was filed  November 9, and 21 days  thereafter  was
November 30.

         Though  I  suspect  that  the  reasons  for our  late  response  are of
diminishing  importance to you, we would like you to know that  immediately upon
filing our Form 10-KSB,  we were forced to focus our  resources  upon filing our
Form 10-QSB for the three months ended  September  30,  2005.  In addition,  our
corporate counsel has recently resigned.  Our filings are now up to date, and we
fully intend to provide a complete  response to your letter by Monday,  December
19.

         I  respectfully  ask that you do not  interpret our failure to meet our
previous  commitments  to respond to your letter as an  indication  that we take
this  matter  lightly.  In fact  we do not  want  to  file a less  then  compete
response,  but would prefer to take the time  necessary to provide  complete and
thorough information. Additionally, the fact that our staff has been overwhelmed
at the moment is an indication  not of problems,  but of success and growth.  We
are currently  developing plans to add to our  administrative  staff in order to
comply with all SEC filings and requests in timely and  complete  fashion in the
immediate future.

         We thank you in advance for your  assistance  in this matter and should
you have any questions, do not hesitate in calling me.


                                          Sincerely,


                                          FREESTAR TECHNOLOGY
                                          CORPORATION

                                          /s/  Paul Egan
                                          --------------------------
                                          Paul Egan
                                          President and Chief Executive Officer