[GRAPHIC OMITTED] HORIZON LAW GROUP LLP tffrench@horizonlawgroup.com July 17, 2006 VIA EDGAR AND FAX Stephen G. Kirkorian Branch Chief - Accounting U.S. Securities and Exchange Commission Division of Corporate Finance 100 F Street, N.E. Washington, D.C. 20549 Re: FreeStar Technology Corporation Form 10-KSB for June 30, 2005 Forms 10-QSB for the fiscal quarters ended September 30, 2005, December 31, 2005 and March 31, 2006 File No. 0-28749 Dear Mr. Kirkorian: We are legal counsel to FreeStar Technology Corporation. This letter is a follow-up to the telephone conversation today between Tamara Tangen of your office and Eric Hopkins of FreeStar Technology Corporation regarding your letter of July 6, 2006. Your July 6, 2006 letter to the Company requested that the Company file its response within 10 business days, or inform you when it would provide a response. As discussed in the telephone conversation earlier today, the Company plans to file its response to your July 6 letter and the corresponding amendments to the above-referenced reports by July 24, 2006. Accordingly, the Company respectfully requests an extension of time until July 24, 2006 to allow the Company and its advisors to fully research and prepare complete and accurate responses to the comments. We thank you in advance for your assistance in this matter and should you have any questions, please do not hesitate to call me at (949) 261-2500. Sincerely, /s/Thomas M. Ffrench -------------------- Thomas M. Ffrench cc: Ciaran Egan, FreeStar Technology Corporation