SecProbe.io

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Room 4561

      July 19, 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
Filed March 31, 2005
   File No. 001-05996

Dear Mr. Munden:

      We have reviewed your response to our letter dated June 13,
2005 in connection with our review of the above referenced filing
and
have the following comments.  Where indicated, we think you should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with supplemental information so we may better
understand your disclosure.  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 your response to prior comment no. 1.  Based on your
specific facts and circumstances, we will not object to the use of
a
Canadian audit firm.  However, if your assets and operations in
the
United States become significant in the future, we expect you to
engage a U.S. registered public accounting firm, consistent with
our
position outlined 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
.

* * * * *

      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.

	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.
July 19, 2005
Page 1

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