Exhibit 14
                        CODE OF BUSINESS CONDUCT & ETHICS

         Introduction

         This Code of Business  Conduct and Ethics (the "Code") sets forth legal
and ethical standards of conduct for directors,  officers and employees of Tiger
Telematics,  Inc. (the "Company"). This Code is intended to deter wrongdoing and
to promote the conduct of all Company business in accordance with high standards
of integrity and in compliance  with all applicable laws and  regulations.  This
Code  applies to the  Company  and all of its  subsidiaries  and other  business
entities controlled by it worldwide.

         All employees,  officers, and directors shall deal honestly, ethically,
and fairly with the Company's employees,  competitors,  customers and suppliers.
Any statement made regarding the Company's products and or services must be true
and not be misleading,  deceptive or fraudulent.  All employees,  officers,  and
directors  shall  follow the  letter  and  spirit of this Code in all  dealings,
whether or not in his or her official capacity as an employee,  officer,  and/or
director.

         Compliance with Applicable Laws

         Employees,  officers,  and directors  must comply with all of the laws,
rules,  and  regulations of the United States and other countries along with the
states,  counties,  cities,  and other  jurisdictions,  applicable to either the
Company or its  business.  This Code does not  summarize  all laws,  rules,  and
regulations applicable to the Company or its business.

         It is the  responsibility of the director,  officer,  employee,  or any
third  party  doing  business  on behalf of the  Company  to  promptly  report a
violation of any law,  rule or  regulation by the Company to a supervisor or the
Company's  Chief  Executive  Officer  (the  "Compliance  Officer").   Employees,
officers, and directors shall not discharge,  demote, suspend,  threaten, harass
or in any other manner  discriminate or retaliate against an employee because he
or she reports any such  violation,  unless it is determined that the report was
made with  knowledge  that it was  false.  This Code shall not be  construed  to
prohibit  any  individual  subject  to  it  from  testifying,  participating  or
otherwise assisting any state or federal administrative, judicial or legislative
proceeding or investigation.

         Conflicts of Interest

         Employees,  officers,  and directors  must act in the best interests of
the Company.  Employees,  officers,  and directors must refrain from engaging in
any  activity  or having a  personal  interest  that  presents  a  "conflict  of
interest." A conflict of interest occurs when your personal interest interferes,
or appears to  interfere,  with the  interests  of the  Company.  A conflict  of
interest can arise  whenever  you, as an employee,  officer,  or director,  take
action or have an interest that prevents you from performing your Company duties
and responsibilities honestly, objectively and effectively.

<PAGE>

         Employees and officers must not:

         o    perform  services as a consultant,  employee,  officer,  director,
              advisor or in any other capacity,  or permit any close relative to
              perform  services  as an officer or  director,  for a  significant
              customer,   significant  supplier  or  direct  competitor  of  the
              Company, other than at the request of the Company;

         o    have, or permit any close  relative to have, a financial  interest
              in a significant  supplier or significant customer of the Company,
              other than an investment  representing  less than one percent (1%)
              of the outstanding shares of a publicly-held  company or less than
              five percent (5%) of the  outstanding  shares of a  privately-held
              company;

         o    have, or permit any close  relative to have, a financial  interest
              in a direct  competitor  of the Company,  other than an investment
              representing less than one percent (1%) of the outstanding  shares
              of a publicly-held company;

         o    supervise,  review or influence the job evaluation or compensation
              of a member of his or her immediate family; or

         o    engage in any other  activity or have any other  interest that the
              Board of  Directors  of the Company  determines  to  constitute  a
              conflict of interest.

         Corporate Opportunity

         Except as may be approved by the Board of  Directors  or a committee of
independent  directors,  directors are prohibited from (a) taking for themselves
personally  any  opportunities  that  belong to the  Company  or are  discovered
through the use of  corporate  property,  information,  or  position;  (b) using
corporate  property,  information,  or  position  for  personal  gain;  and  (c)
competing with the Company.

         Insider Trading

         To help ensure that you do not engage in prohibited insider trading and
avoid even the appearance of an improper transaction, the Company has adopted an
insider  trading  policy.  Employees,  officers and  directors who have material
non-public  information  about the  Company or other  companies,  including  our
suppliers and customers,  as a result of their relationship with the Company are
prohibited by law and Company  policy from trading in securities of the Company,
as well as from  communicating such information to others who might trade on the
basis of that information.

         If you are uncertain  about the constraints on your purchase or sale of
any Company  securities,  you should consult with the Compliance  Officer before
making any such purchase or sale.


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<PAGE>

         Confidentiality

         Employees,  officers and directors must maintain the confidentiality of
confidential information entrusted to them by the Company or its subsidiaries or
affiliates,  including our suppliers and  customers,  except when  disclosure is
authorized by a supervisor or legally mandated.  Unauthorized  disclosure of any
confidential  information is  prohibited.  Additionally,  employees  should take
appropriate  precautions  to ensure  that  confidential  or  sensitive  business
information,  whether it is  proprietary to the Company or its  subsidiaries  or
affiliates,  is not communicated within the Company except to employees who have
a need to know  such  information  to  perform  their  responsibilities  for the
Company.

         Third parties may ask you for information concerning the Company or its
subsidiaries  or affiliates.  Subject to the  exceptions  noted in the preceding
paragraph,   employees,   officers  and  directors  (other  than  the  Company's
authorized  spokespersons)  must not discuss  internal  Company matters with, or
disseminate internal Company information to, anyone outside the Company,  except
as required in the  performance of their Company duties and after an appropriate
confidentiality  agreement is in place. This prohibition applies particularly to
inquiries  concerning the Company from the media, market  professionals (such as
securities analysts,  institutional investors,  investment advisers, brokers and
dealers)  and  security  holders.  All  responses  to inquiries on behalf of the
Company  must be made only by the  Company's  authorized  spokespersons.  If you
receive any inquiries of this nature,  you must decline to comment and refer the
inquirer to your supervisor or one of the Company's authorized spokespersons.

         You also must  abide by any  lawful  obligations  that you have to your
former  employer.  These  obligations  may include  restrictions  on the use and
disclosure of  confidential  information,  restrictions  on the  solicitation of
former colleagues to work at the Company and non-competition obligations.

         The  Company  has  designated  the  Chief  Executive   Officer  as  its
Compliance Officer to administer this Code. Directors, at their discretion,  may
make any report or  complaint  provided  for in this Code to the Chairman of the
Board of the Company or to the Compliance  Officer.  The Compliance Officer will
refer  complaints  submitted,  as  appropriate,  to the  Chair of the  Company's
Nominating,  Compensation,  or  Governance  Committee  or to the  full  Board of
Directors.

         Directors are encouraged to promptly  contact the Chairman of the Board
or the Compliance  Officer if the director  believes that he or she has observed
illegal or unethical  behavior by any  employee,  officer,  or  director,  or by
anyone  purporting  to be acting on either  Company's  behalf and, the reporting
director  has any  doubt  about  the  best  course  of  action  in a  particular
situation.  Any such reports may be made  anonymously.  Confidentiality  will be
maintained, to the extent permitted by law.


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<PAGE>

         Whistleblower Policy

         This Code requires all directors, officers and employees of the Company
to comply with the letter and spirit of applicable  laws and  regulations.  This
Whistleblower  Policy is intended to encourage and enable any director,  officer
or employee of the Company to raise  serious  concerns  about  unlawful or other
inappropriate  activities.   This  Whistleblower  Policy  is  also  intended  to
encourage proper individual conduct and accountability and to alert the Company,
including any committee of the Company, of ongoing or potential serious problems
at an early stage.

         Each director, officer or employee is required to comply with this Code
and to  report  violations  or  suspected  violations  in  accordance  with this
Whistleblower Policy and the remaining provisions of this Code.

                  Reporting Procedure.
                  -------------------

         This Code provides for two different methods of reporting violations or
suspected  violations.  First,  the  whistleblower  may directly address serious
concerns or complaints  regarding financial or accounting matters,  unethical or
illegal  conduct,  any  violation  of this Code,  or other  appropriate  matters
directly to the Chief Executive Officer at:

                           550 Water Street, Suite 937
                           Jacksonville, Florida 32202
                           (904) 358-1512

         Alternatively,  the  whistleblower  may report  complaints  or concerns
regarding any serious matter at any time on a  confidential,  anonymous basis to
the Chief Executive Officer at the address listed above.

         Employment  and  workplace-related   concerns  should  continue  to  be
reported  and  addressed  through  normal  channels,   such  as  your  immediate
supervisor,   human  resources  representative  or  other  such  contact.  These
workplace-related concerns will continue to be addressed by human resources.

                  Action on Complaints.
                  --------------------

         Upon  receipt of a  complaint,  whether  directly or  anonymously,  the
Compliance  Officer will (1) determine,  in  consultation  with other  executive
officers  whether the  complaint  or concern  pertains to  accounting,  internal
accounting  controls,  or auditing matters and (2)  acknowledge,  when possible,
receipt of the complaint to the whistleblower.

         If the complaint relates to an accounting, internal accounting control,
or  auditing  matter,  then the Chief  Financial  Officer  and  Chief  Executive
Officer,  and any  other  persons  that the  Chief  Financial  Officer  or Chief
Executive  Officer  determine  appropriate  must  review the  complaint.  Unless
reported to the Audit  Committee,  all such  complaints  will be reported to the
Audit  Committee  no less  than  quarterly.  The  review  will be  handled  on a

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<PAGE>

confidential  basis to the  fullest  extent  possible.  Prompt  and  appropriate
corrective action will be taken when in the best judgment of the Chief Financial
Officer, Chief Executive Officer or Audit Committee recommends.

         No one who in good faith  reports a violation of this Code or any other
concern under the Whistleblower  Policy shall suffer harassment,  retaliation or
adverse employment consequences. An employee that retaliates against someone who
has  reported a  violation  in good faith is  subject  to  discipline  up to and
including termination of employment.

         Waivers of this Code

         Some exceptions to this Code may be possible. However, many policies in
this Code must be strictly adhered to and no exceptions are allowed.  Any person
that  believes  an  exception  applies  and  is  appropriate  in  light  of  all
surrounding  circumstances must contact the Compliance  Officer.  The Compliance
Officer is responsible  for  maintaining a complete  record of all such requests
for exceptions to this Code and the disposition of such requests.

         Dissemination And Amendment

         This  Code  shall be  distributed  to each new  employee,  officer  and
director of the Company  upon  commencement  of his or her  employment  or other
relationship  with the  Company and shall also be  distributed  annually to each
employee,  officer and director of the Company,  and each employee,  officer and
director  shall  be  asked  to  certify  that he or she has  received,  read and
understood  the Code and has complied  with its terms and intends to comply with
its terms in the future.

         The Company  reserves the right to amend,  alter or terminate this Code
at any time for any reason.

         This document is not an employment contract between the Company and any
of its employees, officers or directors.






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