April 27, 2005


Mail Stop 04-09

Charles A. Menendez
1545 Miller Road
Coral Gables, FL 33146

Re:	Default Proof Credit Card System, Inc.
	Form 10- KSB/A for the year ended December 31, 2004
	File No. 000-24444

Dear Mr. Menendez:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  As such, all persons who are responsible for the
adequacy
and accuracy of the disclosure are urged to be certain that they
have
included all information required pursuant to the Securities
Exchange
Act of 1934.

      Where indicated, we think you should revise your documents
in
response to these comments.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.
Form 10-KSB

Item 7 - Management`s Discussion and Analysis of Financial
Conditions
and Results of Operations

Controls and Procedures

1. How does your evaluation of disclosure controls and procedures
as
of 90 days prior to the filing date comply with the requirements
in
Item 307 of Regulation S-B to conclude on the effectiveness as of
the
end of the period covered by the report?

Item 8 - Financial Statements

Independent Auditor`s Report
2. Supplementally explain to us how you considered PCAOB Auditing
Standard No. 1 with regards to making reference to the standards
of
the Public Company Accounting Oversight Board within your
independent`s audit report or revise, accordingly.

Note 10 - Due to a Related Party
3. We note that you recorded an extraordinary gain for the
reduction
of amounts due to an executive officer in the amount of $20,000.
Tell us how you determined that it was appropriate to record the
forgiveness of debt by a related party as a gain rather than
contributed capital.  Reference is made to footnote 1 in paragraph
20
of APB 26.  Further, how did you determine your presentation of
this
amount as extraordinary complied with SFAS 145?

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.


      You may contact Yolanda Crittendon, at (202) 942-1868 or the
undersigned at (202) 942-1975 if you have questions.



						Sincerely,



Cicely Luckey
Branch Chief

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Default Proof Credit Card System, Inc.
April 27, 2005
Page 1