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                            [TROYGOULD LETTER HEAD]

                                October 17, 2005

                                                                          2066-1
VIA ELECTRONIC TRANSMISSION

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0405

      Re:   Natural Gas Systems, Inc. - Amendment No. 1 to Registration
            Statement on Form SB-2 - Registration No. 333-125564
            -----------------------------------------------------------

Dear Sir or Madam:

      On behalf of Natural Gas Systems, Inc., a Nevada corporation (the
"Company"), we have enclosed for filing under the Securities Act of 1933
Amendment No. 1 to the Registration Statement on Form SB-2, Registration No.
333-125564 (the "Registration Statement"), including the exhibits thereto, that
was initially filed with the Securities and Exchange Commission (the
"Commission") on June 6, 2005. We have supplementally also enclosed a copy of
Amendment No. 1 that has been marked to show the changes that have been made to
the initial filing of the Registration Statement. Amendment No. 1 to the
Registration Statement includes an amended prospectus (the "Prospectus").

      By its letter dated July 5, 2005, the staff of the Commission (the
"Staff") provided the Company with comments on the Registration Statement. We
have set forth below the responses of the Company to the Staff's comments. The
numbers of the responses set forth below correspond to the numbered comments in
the July 5 letter from the Staff.

Selling Stockholders

      1.    (A) Based on the Company's survey of the selling stockholders, none
            of the selling stockholders are currently broker-dealers (other than
            James F. George, as discussed below) and the only persons/entities
            that are currently affiliates of broker-dealers are James F. George,
            Joseph B. Childrey, Linden Growth Partners, L.P., Peter Rettman and
            Richard From (collectively, the "B/D Affiliate Selling
            Stockholders"). We have not, however, identified any of the B/D
            Affiliate Selling Stockholders as underwriters because at the time
            of their purchases, none of the B/D Affiliate Selling Stockholders
            had any agreements or understandings, directly or indirectly, with
            the brokers with whom they are affiliated with or with any broker or
            other person, to distribute the shares, and the shares were acquired
            in the ordinary course of business. Disclosure to this effect has
            been added to the "Selling Stockholders" section.

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            Additionally, the economics and mechanics of transactions in which
            the B/D Affiliate Selling Stockholders acquired their shares clearly
            indicate that they were not conduits in connection with a primary
            offering by the Company for a number of reasons, including the
            following:

            (i)   The shares (other than those held by Mr. From), were all
                  acquired pursuant to the terms of the merger of the private
                  company, Natural Gas Systems, Inc., into the public entity
                  Reality Interactive (now the Company), that was completed over
                  one year ago. As set forth in footnote 13 to the table of
                  Selling Stockholders, Mr. From acquired his shares from Cagan
                  McAfee Capital Partners ("CMCP") over one year ago in
                  connection with consulting services performed on CMCP's
                  behalf.

            (ii)  The Company will not receive any proceeds from the resale of
                  these shares and accordingly, none of the B/D Affiliate
                  Selling Stockholders can be considered to be engaged in a
                  primary offering by the Company.

            (B) James F. George is a broker with Countrywide Securities, Inc.
            ("Countrywide"), a dealer in US bonds and mortgages only.
            Countrywide does not act as a broker dealer with respect to equity
            securities. For this reason, as well as the reasons set forth above
            in paragraph 1(A), Mr. George has not been identified as an
            underwriter. Disclosure to this effect has been added to the
            "Selling Stockholders" section.

      2.    In the footnotes to the "Selling Stockholders" table, we have
            identified the natural persons who have voting and investment
            control over the shares offered for resale by the entities that are
            listed as selling stockholders. We have also added explanatory
            footnotes in the case where more than one holder is listed as
            beneficial owner for the same securities listed in the "Selling
            Stockholders" table.

Plan of Distribution

3.    We have amended this section to disclose that no short sales may occur
      prior to effectiveness of the Registration Statement.

Experts

4.    We have identified W.D. Von Gonten & Co. as experts and have filed their
      consent as an exhibit.

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Financial Statements

      5.    Pursuant to a series of phone conservations and correspondence with
            members of the Staff, we understand that the Staff has agreed that
            this comment will be adequately addressed if we include the
            Company's audited financial statements for the fiscal year ended
            June 30, 2005, which we have done.

Risk Factors

      6.    The Company does not discuss unleased prospects anywhere in the
            prospectus; accordingly, the sentence has been removed.

Management's Discussion and Analysis

      7.    The applicable term with respect to W.D. Von Gonten & Co.'s report
            is "prepared" We have amended all references in the document to such
            report to state that it was prepared by Von Gonten. In addition, we
            have added a definition of "prepared" in the context of petroleum
            reserve estimation in the "Glossary of Selected Petroleum Terms."

Proved Reserves

      8.    We have eliminated the summation of proved reserves estimated at
            different dates. We have also added disclosure regarding each
            acquisition, its associated proved reserves, purchase price and
            other pertinent information, by providing: a) reserve information in
            the Tullos Field Property description in the "Business" section, and
            (b) additional information in the footnotes of the Proved Reserve
            table in Note 10, "Supplemental Oil and Gas Disclosures," to our
            consolidated financial statements. We have corrected the $8.71/MCF
            price by changing it to the $6.19 NYMEX price used in our reserve
            report.

Business

      9.    We have added the required disclosure to the risk factor entitled
            "The Types ff Resources We Focus on Have Certain Risks".

Tullos Field Area

      10.   We have removed this disclosure throughout the prospectus.

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Glossary of Terms

      11.   We have added a definition of "PV-10" to the glossary.

Supplemental Oil and Gas Disclosures (Unaudited)

      12.   We have added footnote disclosure to the table of net proved
            reserves to explain the 270 MMCFG negative revision to the Company's
            July 1, 2004 proved gas reserves. We have also disclosed "revisions"
            as a line item separate from extensions and discoveries throughout
            the table.

General

      In addition to effecting the changes discussed above, the Company has made
various other changes and has endeavored to update the information in the
Registration Statement.

      Please direct questions regarding the amended Registration Statement
(other than questions regarding accounting matters) to the undersigned at
310-789-1255. Questions regarding accounting matters should be addressed to
Sterling McDonald, the Company's Chief Financial Officer, at 713-935-0122.

                                        Very truly yours,

                                        TROY & GOULD


                                        /s/ Lawrence P. Schnapp

                                        Lawrence P. Schnapp

Enclosures

cc:   Robert S. Herlin
      Sterling H. McDonald
      Steven D. Lee, Esq.
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