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

July  26  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  JUNE  8,  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 initially filed a response letter
dated  July 13, 2006 as correspondence on EDGAR, specifically addressing comment
number  1  of  your letter dated June 28, 2006.  We are, at this time, filing an
amended  SB-2  Registration  Statement in response to your June 28, 2006 comment
letter.  All  changes  are  indicated  with  revision  marks.

     Our  responses  to  your  comments  follow  below.

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

     1.     For  the reasons stated in our letter dated July 13, 2006, and based
upon  our  subsequent discussions, we have not listed the affiliates of Cytation
as  underwriters  in  connection  with  the  resale  registration  statement.

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

     2.     We  have amended the disclosures entitled "Certain Relationships and
Related Transactions" in the Registration Statement to make them consistent with
the  same  disclosures in our definitive 14C Information Statement.  Please note
that  we  have  also amended the remainder of the Registration Statement, to the
extent  necessary,  to  bring  it  into  conformity  with  our  definitive  14C
Information  Statement.

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Underwriters  and  Underwriting  Obligation,  page  28
- ------------------------------------------------------

     3.     In addition, we have removed Midtown Partners & Co., LLC, an SEC and
NASD  registered  broker-dealer,  from  the  section  titled  "UNDERWRITERS  AND
UNDERWRITING  OBLIGATION"  on  page 28.  We have removed Midtown Partners & Co.,
LLC  because  all  of  the securities owned by Midtown Partners were received as
payment  of commissions earned as placement agent for the Cytation in connection
with  Cytation's  Series  A  and  Series  D  preferred  stock private offerings.

     If you should have any questions regarding our amended Registration
Statement, 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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