SecProbe.io

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Room 4561

      June 13, 2005

Mr. Edward Munden
Director, Chairman, President and
Chief Executive Officer
DataJungle Software, Inc.
1 Hines Road, Suite 202
Ottawa, Ontario, Canada K2K 3C7

      Re:	DataJungle Software, Inc.
   Form 10-KSB for the year ended December 31, 2004
Form 10-QSB for the quarter ended March 31, 2005
   File No. 001-05996

Dear Mr. Munden:

      We have reviewed your filings and have the following
comments.
Please note that we have limited our review to only your financial
statements and related disclosures and do not intend to expand our
review to other portions of your document.  We may ask you to
provide
us with supplemental information so we may better understand your
disclosure.  Please be as detailed as necessary in your
explanation.
After reviewing this information, we may raise additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-KSB

Report of Independent Registered Public Accounting Firm, page 33
1. We note that your audit report was signed by an audit firm
based
in Ottawa, Canada.  Please tell us how you concluded that it is
appropriate to have an audit report issued by an auditor licensed
outside of the United States. In accordance with Article 2 of
Regulation S-X, we believe that the audit report of a registrant
(that is not a foreign private issuer) should ordinarily be
rendered
by an auditor licensed in the United States.  Further guidance may
be
found in Section 5.K of "International Reporting and Disclosure
Issues in the Division of Corporation Finance" on the Commission`s
website at:
http://www.sec.gov/divisions/corpfin/internatl/cfirdissues1104.htm
#P4
42_69217.  Please tell us (1) where the majority of your revenues
are
earned, (2) where the majority of your assets are located, (3)
where
your management and accounting records are located and (4) where
the
majority of the audit work is conducted.  We may have further
comments.

Note 10. Promissory Note Payable to Related Party, page 48
2. We note you have a note payable to a related party that is
convertible into common stock.  Provide to us your analysis of any
beneficial conversion features that may have existed related to
this
convertible note and your accounting treatment for any such
features.
Also, tell us how you considered EITF 98-5 and EITF 00-27 in
accounting for the related party notes payable.

Note 11. Stockholders` Deficiency, page 49

3. We note you incurred $290,011 of issuance costs related to the
sale of your common stock to certain investors during the year
ended
December 31, 2004.  Provide us with a detailed listing of these
fees
by major category and who these fees were paid to.  Also tell us
how
you determined the 294,075 shares issued in exchange for such
costs.

* * * * *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing any amendment and your responses to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Patrick Gilmore at (202) 551-3406, Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 or me at (202)
551-3730 if you have questions regarding comments on the financial
statements and related matters.

							Sincerely,

							Craig Wilson
							Senior Assistant Chief
Accountant

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Mr. Edward Munden
DataJungle Software, Inc.
June 13, 2005
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