
Cytation  Corporation
4902  Eisenhower  Blvd.
Suite  185
Tampa,  Florida  33634
(813)  885-5998

June  8,  2006


United  States  Securities  and  Exchange  Commission
Division  of  Corporation  Finance
Attn:  Pamela  Long,  Assistant  Director
100  F  Street,  N.E.
Washington,  D.C.  20549-7010

     RE:     CYTATION  CORPORATION
             REGISTRATION  STATEMENT  ON  FORM  SB-2
             FILE  NO.  333-133377
             FILED  APRIL  19,  2006

Dear  Ms.  Long,

     We  received  your  letter commenting on the Registration Statement on Form
SB-2  ("Registration Statement") filed on April 19, 2006 by Cytation Corporation
(the  "Company").  In  connection  with  your  comments,  we have made necessary
changes  suggested  in  your  letter  and  filed them in an amended Registration
Statement,  filed  via EDGAR on June 8, 2006.  In addition, we have filed a copy
of this letter as correspondence on EDGAR.  We have placed revision marks at the
beginning  and  end  of  each  material  change  in  the  Registration Statement
(punctuation  and  spelling  changes  are  not  marked).  Changes  to tables are
denoted  by  revision  marks  at  the  beginning  and  end  of  each  table.

     Our  responses  to  your  comments  follow  below.

General
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1.   We have  added  the  following  disclosure to the Registration Statement on
     page  50.

          Some  affiliates  of  Deer  Valley  Homebuilders, Inc. ("Deer Valley")
          purchased  shares  in  the  Series  A  Preferred Stock Offering, which
          closed  on January 18, 2006. The following eight former owners of Deer
          Valley  purchased  an  aggregate  of  $500,000  in  shares of Series A
          Convertible  Preferred Stock, Series A Common Stock Purchase Warrants,
          and  Series  B  Common  Stock  Purchase  Warrants: Joel Logan, Charles
          Murphree, John Steven Lawler, James David Shaw, William Joseph Aycock,
          Jr.,  Jerry  Ray Cooper, Jr., Timm Gann, and Jimmy Ray Hawkins. In the
          aggregate,  the eight former owners of Deer Valley acquired (a) 66,666
          shares  of  Series  A  Convertible  Preferred  Stock  convertible into
          666,666  shares  of  common  stock, (b) Series A Common Stock Purchase
          Warrants  exercisable  for  666,666  shares  of  common stock, and (c)
          Series B Common Stock Purchase Warrants exercisable for 666,666 shares
          of  common  stock.

<PAGE>

2.   In connection  with  the  "Share Exchange," the shareholders of Deer Valley
     Acquisitions  Corp. received Series B Convertible Preferred Stock, Series C
     Convertible Preferred Stock, and Series C Common Stock Purchase Warrants of
     Cytation  Corporation  in  exchange  for  one hundred percent (100%) of the
     issued  and  outstanding  capital  stock  of Deer Valley Acquisitions Corp.
     Thus,  as  a  result of the Share Exchange on January 18, 2006, Deer Valley
     Acquisitions  Corp.  became  a  wholly-owned  subsidiary  of  Cytation
     Corporation.  Immediately  after completion of the Share Exchange, but also
     on  January  18,  2006, Deer Valley Acquisitions Corp. acquired one hundred
     percent  (100%)  of the issued and outstanding capital stock of Deer Valley
     Homebuilders,  Inc.

     On  page  51  of  the  Registration  Statement  under  the  heading  "Share
     Exchange,"  we  have  noted  that  Deer  Valley Acquisitions Corp. became a
     wholly-owned  subsidiary  of  Cytation Corporation as a result of the Share
     Exchange.  On  page  52  of  the  Registration  Statement under the heading
     "Acquisition,"  we  have  clarified  that  the  acquisition  of Deer Valley
     Homebuilders,  Inc.  occurred  on  January  18,  2006  immediately  after
     completion  of  the  Share  Exchange.

Cover  Page  of  Prospectus
- ---------------------------

3.   We have corrected the discrepancies noted in this comment. Specifically, we
     have  revised the number of common shares in the third bullet point on page
     3  to  read "2,675,000" and have revised the number of common shares in the
     penultimate  bullet  point  on  page  20  to  read  "2,087,742."

Selling  Shareholders
- ---------------------

4.   On pages  9  and  19  of  the  Registration Statement we have disclosed the
     dividend  rate  on  the Series A Convertible Preferred Stock and included a
     cross-reference  to  page  56  of  the  Registration  Statement,  where the
     dividend  rate  for  the  Series  A Preferred Stock is disclosed in greater
     detail.

5.   On pages  9  and  20 we have disclosed when the Company incurs registration
     penalties, the amount currently payable, the terms of any securities issued
     in  connection  with  the registration penalties, and to whom the penalties
     will be payable. We have also included a more detailed discussion regarding
     the  registration  penalties  on  page  51.

6.   We have  added  a  "TOTAL"  row  at the end of the selling security holders
     table,  which  begins  on  page  21.

<PAGE>

7.   We have  added the following additional disclosures pursuant to Item 508 of
     Regulation  S-B  after the heading "Plan of Distribution" on page 32 of the
     Registration  Statement:

UNDERWRITERS  AND  UNDERWRITING  OBLIGATION

          One  selling  stockholder,  Midtown  Partners  &  Co.,  LLC  ("Midtown
          Partners"),  is  a  SEC  and  NASD  registered  broker-dealer. Midtown
          Partners  acted  as  the placement agent for the Company in connection
          with  the Series A Preferred Stock Offering and the Series D Preferred
          Stock  Offering.  Midtown  Partners received the following warrants as
          partial  payment  of  commissions  earned  as  placement agent for the
          Company  in  connection  with  such private offerings: (a) Series BD-1
          Common  Stock  Purchase  Warrants  exercisable  for, in the aggregate,
          889,162  shares  of  Common Stock at an exercise price of seventy five
          cents ($.75) per share, (b) Series BD-2 Common Stock Purchase Warrants
          exercisable  for,  in the aggregate, 889,162 shares of Common Stock at
          an exercise price of one dollar and fifty cents ($1.50) per share, (c)
          Series  BD-3  Common  Stock  Purchase Warrants exercisable for, in the
          aggregate,  449,581 shares of Common Stock at an exercise price of two
          dollars  and  twenty  five  cents  ($2.25)  per share, (d) Series BD-4
          Common  Stock  Purchase  Warrants  exercisable  for, in the aggregate,
          61,120  shares  of Common Stock at an exercise price of one dollar and
          fifty  cents  ($1.50)  per  share,  and  (e)  Series BD-5 Common Stock
          Purchase  Warrants exercisable for, in the aggregate, 61,120 shares of
          Common  Stock  at an exercise price of three dollars ($3.00) per share
          (collectively,  the  "BD  Warrants").  Pursuant  to  this registration
          statement,  the  Company  is  registering for re-sale the common stock
          issuable  upon  exercise  of the BD Warrants. As such, relative to the
          shares  issuable  upon  exercise  of the BD Warrants, Midtown Partners
          falls  into  the definition of an "underwriter," as defined in Section
          2(11)  of  the  Securities  Act  of  1933,  as  amended.

          In  addition,  the  following  selling  shareholders are affiliates of
          Midtown  Partners:  (a)  Apogee Financial Investments, Inc., a selling
          shareholder  holding  1,901  shares  of  Series  B  Preferred  Stock
          convertible  into  190,100 shares of common stock; (b) Famalom, LLC, a
          selling  shareholder  holding 3,025 shares of Series B Preferred Stock
          convertible  into  302,500  shares  of  common  stock;  (c)  Daedalus
          Consulting, Inc., a selling shareholder holding 3,425 shares of Series
          B Preferred Stock convertible into 342,500 shares of common stock; (d)
          Deecembra  Diamond,  a  selling  shareholder  holding  5,750 shares of
          Series  B  Preferred  Stock  convertible into 575,000 shares of common
          stock;  and  (e)  Total CFO, LLC, a selling shareholder holding 26,750
          shares  of  Series B Preferred Stock convertible into 2,675,000 shares
          of  common  stock  and  a  Series  C  Common  Stock  Purchase  Warrant
          exercisable  for  2,000,000  shares of common stock (collectively, the

<PAGE>

          "Midtown  Affiliates").  The  Company  is  registering for re-sale the
          common  stock  issuable  upon exercise or conversion of the securities
          referenced  above  in  this  paragraph.  As  such,  as an affiliate of
          Midtown  Partners,  the  selling shareholders referenced above in this
          paragraph  fall into the definition of an "underwriter," as defined in
          Section  2(11)  of the Securities Act of 1933, as amended, relative to
          the  securities  owned  by  each  such  selling  securityholder  being
          registered  hereunder.

          Except  for  the  prior  engagement  of  Midtown Partners as placement
          agent in connection with the private Series A Preferred Stock Offering
          and  the private Series D Preferred Stock Offering, and as an owner of
          securities,  Midtown  Partners  does  not have a material relationship
          with  the  Company.  Further,  except as an owner of securities of the
          Company,  none  of the Midtown Affiliates have a material relationship
          with  the  Company.  Neither  Midtown  nor  the Midtown Affiliates may
          return  any  of  the  above referenced securities. Please see page 138
          below for a description of offering expenses. Also, please see "SERIES
          A  PREFERRED  STOCK OFFERING" on page 49 and "SERIES D PREFERRED STOCK
          OFFERING"  on  page  53  for a description of the compensation Midtown
          Partners  received  for  its  services as placement agent. There is no
          arrangement  under which Midtown Partners or any Midtown Affiliate may
          purchase  additional  shares  or  securities  in connection with these
          offerings.  Midtown  Partners has no contractual right to designate or
          nominate a member of the Board of Directors. Midtown Partners has been
          in  business  as a registered broker-dealer for more then three years.
          Previously,  Midtown  Partners  had operated under the name Innovation
          Capital, LLC. No finders or other licensed Broker-Dealers were used by
          the  Company in connection with the Series A Preferred Stock Offering,
          the Series B Preferred Stock Offering, or this Registration Statement.

          Midtown  Partners  and  each  of  the  Midtown  Affiliates  plan  to
          resale  the  above  referenced  securities  pursuant  to  the  plan of
          distribution  as  discussed at page 31 under the heading "DISTRIBUTION
          METHOD."  Based  upon  representations  received, Midtown Partners and
          each  of  the  Midtown  Affiliates  do not intend to engage in passive
          market  making  transactions  under  Rule  103  of  Regulation M or to
          conduct  any stabilizing transactions. Midtown and each of the Midtown
          Affiliates  are  not making any warrant or rights offering to existing
          security  holders.

          The  placement  agent  agreement  between  Midtown  Partners  and  the
          Company  provides  for  indemnification  of  Midtown  Partners  by the
          Company  for  losses,  claims,  damages,  or  liabilities,  including
          attorneys'  fees,  incurred  by  Midtown  Partners  in connection with
          Midtown  Partners'  services  as  a  placement  agent.  The  Company's
          obligation  to  indemnify  Midtown  Partners would include liabilities
          arising  under  the  Securities  Act  of  1933.  This  indemnification
          provision  is  limited  by  a  proviso  that  if  such losses, claims,

<PAGE>

          damages, or liabilities are found by a court to arise primarily out of
          Midtown  Partners'  violation  of  any  applicable  law,  then Midtown
          Partners  must  repay  to  the  Company  any  amounts  received  as
          indemnification.

8.   Via footnotes  to  the  table  of selling security holders, which begins on
     page  21,  we  have  disclosed  the natural person(s) having sole or shared
     voting  and  investment  control  over  the  securities  held  by  selling
     stockholders  which  are  not  natural  persons.

9.   We have  added  the  following  disclosure  under  the  caption  "Plan  of
     Distribution-Eligible  Shares"  on  page  30 of the Registration Statement:

          To  the  extent  any  successor(s)  to  the named selling stockholders
          wish  to sell under this prospectus the Company must file a prospectus
          supplement  identifying  such  successors  as  selling  stockholders.

10.  We have  added  the  following  disclosure  to  under  the heading "Selling
     Security  Holders"  on  page  20  of  the  Registration  Statement.

          Sequence  Advisors  Corp.  acquired  its  securities  before  the
          transaction closing in January 2006 to provide a source of funds to be
          used  by  former  management  to  meet post-closing expenses and other
          obligations  and  to  compensate former management for its services to
          the  extent  funds  are  unused. Allison Investment Corp. acquired the
          right  to  purchase  securities  in  exchange  for  relinquishing  its
          exclusive right to locate a merger candidate for Cytation Corporation.
          Subsequently,  Allison  Investment  Corp.  exercised  that  right  and
          purchased  its  securities  from  the Company. Please refer to "Recent
          Sales  of  Unregistered  Securities"  on page 139 of this Registration
          Statement  for  information  on  how  holders of Series A, B, C, and D
          Preferred  Stock  and  holders  of Series A, B, C, D, E, and BD Common
          Stock  Purchase  Warrants  acquired  their  securities.

11.  Bush Ross,  P.A.  has filed its opinion as Exhibit 5.01 to the Registration
     Statement.

     If you should have any questions regarding our amended Schedule 14C, please
do not hesitate to contact me.


                                Sincerely,


                                /s/ Charles G. Masters
                                ------------------------------
                                Charles G. Masters
                                President & Chief Executive Officer


Cc:     Bush  Ross,  P.A.

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