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

July  13,  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 dated June 28, 2006 commenting on the Registration
Statement  on  Form SB-2 ("Registration Statement") originally filed by Cytation
Corporation  (the  "Company") on April 19, 2006, and amended and refiled on June
8,  2006.  In connection with your comments, we have filed a copy of this letter
as  correspondence  on  EDGAR.  We have not, at this time, filed an amended SB-2
Registration  Statement  in  response  to  your  June  28,  2006 comment letter.

     Our  responses  to  your  comments  follow  below.

Selling  Security  Holders,  page  18
- -------------------------------------

     1. In your response letter, you indicate that Cytation Corporation may have
been  a  blank  check  company  when  it entered into the transactions with Deer
Valley. We also note your reference to the letter dated January 21, 2000, to Mr.
Ken  Worm,  Assistant  Director, OTC Compliance Unit, NASD Regulation, Inc. from
Mr.  Richard  Wulff,  Chief  Office  of  Small  Business.

     Section  7(b)(3) of the Securities Act defines a blank check company as any
development  stage  company  issuing  penny stock (within the meaning of Section
3(a)(51)  of  the  Securities  Exchange  Act  of  1934) that (a) has no specific
business  plan or purpose, or (b) the business plan of which is to merge with an
unidentified  company  or  companies.

     For  the  following  reasons,  we  do not believe that Cytation was a blank
check  company  at  or  about  the  time  (a)  it  completed its preferred stock

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offerings  on  January  18,  2006,  (b) completed the acquisition of 100% of the
common  stock  of Deer Valley Homebuilders, Inc. on January 18, 2006 (though the
acquisition  of  DeerValley  Acquisitions,  Corp),  or  (c)  it  first solicited
potential  purchasers  of  preferred  stock  in  early  December  2005:

- -    In January  2005,  the  buy-out  group  first  contacted the owners of Deer
     Valley  Homebuilders,  Inc.  (a  private  company)  to discuss the possible
     acquisition  of  Deer  Valley  Homebuilders,  Inc.

- -    In contemplation  of  the acquisition of Deer Valley Homebuilders, Inc., on
     June  22,  2005, the buy-out group formed DeerValley Acquisitions, Corp., a
     privately  held  Florida  corporation.  As  its  name reflects, Deer Valley
     Acquisitions,  Inc.  was  formed  specifically for the purpose of acquiring
     ownership  Deer  Valley  Homebuilders,  Inc.

- -    On November  1,  2005,  DeerValley Acquisitions, Corp. entered into a Stock
     Purchase  Agreement  with  Deer  Valley  Homebuilders,  Inc.

- -    On November  7,  2005, Cytation Corporation filed an 8-K announcing that it
     had  entered  into  a  letter of intent with DeerValley Acquisitions, Corp,
     which  such  8-K,  among other matters, announced that Cytation Corporation
     intended  to  acquire Deer Valley Homebuilders, Inc. Prior to entering into
     the  letter  of  intent,  none of the officers, directors, or affiliates of
     Cytation  Corporation  had  any  prior  relationship  with  Deer  Valley
     Acquisitions,  Corp,  Deer  Valley  Homebuilders,  Inc.,  or  the officers,
     directors,  or affiliates of Deer Valley Acquisitions, Corp, or Deer Valley
     Homebuilders,  Inc.

- -    On or about  December 5, 2006, documents were first circulated to potential
     investors.  The  draft  purchase  agreement  specifically provided that all
     closings  on  any  preferred stock offerings by Cytation were contingent on
     the  acquisition  of  Deer  Valley  Homebuilders,  Inc.

- -    All preferred  stock,  i.e., the penny stock issuance referenced in Section
     7(b)(3)  of  the  Securities  Act, was issued by Cytation Corporation on or
     after  January  18,  2006.

- -    In excess  of  99%  of  the  stock  of Cytation being registered for resale
     pursuant  to its SB-2 Registration Statement was issued on or after January
     18,  2006.

     Based  on  the  foregoing,  we  believe that Cytation Corporation was not a
blank check company at the time it completed its transaction with Deer Valley on
January 18, 2006.  In early November 2005, Cytation had identified and announced
its  intend target prior to the commencement of any securities offerings. At the
time  each  investor  made  the  decision  to  acquire  securities  of  Cytation
Corporation,  the  investor  had  knowledge of Cytation's plan of operation, its
intended  target,  Deer Valley Homebuilders, Inc., and intended use of proceeds.
Further,  the issuance of its preferred stock was specifically contingent on the
acquisition  of  Deer  Valley  Homebuilders,  Inc.

     For  your reference with regard to the foregoing, we have supplied to you a
copy  of:  (a)  Letter  of  Intent dated January 21, 2005 to acquire Deer Valley
Homebuilders,  Inc.,  (b)  the  Articles  of  Incorporation  of  DeerValley

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Acquisitions, Corp., (c) the Common Stock Purchase Agreement between Deer Valley
Homebuilders,  Inc  and  DeerValley Acquisitions, Corp., dated November 1, 2005,
(d)  Cytation  Corporation's 8-K, dated November 7, 2006, announcing that it had
entered  into  a  letter  of  intent with DeerValley Acquisitions, Corp, and (e)
excerpts  from  the  Securities  Purchase  Agreement  dated  January  18,  2006.

Certain  Relationships  and  Related  Transactions,  page  39
- -------------------------------------------------------------

     2.  When  we  file  the amended SB-2 Registration Statement, we will revise
this  section  to make it consistent with the same disclosures in our definitive
14C  Information  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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