The audit reports of the Company on its financial statements for the past two fiscal years ended October 31, 2004 and 2005 did not contain any adverse opinion or disclaimer of opinion. The reports for the two years ended October 31, 2005 contained a paragraph raising doubt about the Company's ability to continue as a going concern; otherwise, the reports were not qualified or modified as to uncertainty, audit scope or accounting principles.

During the Company's fiscal year ended October 31, 2005 and the subsequent interim period up to January 16, 2007, there were no disagreements with Miller & McCollom, whether or not resolved, on any matter of accounting principle or practice, financial statement disclosure, auditing scope or procedure which, if not resolved to Miller and McCollom's satisfaction, would have caused Miller and McCollom to make reference to the subject matter of such disagreement in connection with its report on the Company's financial statements for such periods. Miller and McCollom did not audit the Company's financial statements for the fiscal year ended October 31, 2004.

The Company has provided Miller and McCollom, Certified Public Accountants, with a copy of the forgoing disclosures. Attached as Exhibit 16 is a copy of Miller and McCollom's letter dated January 16, 2007 stating its agreement with such statements