SecProbe.io

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Mail Stop 4561

                  September 13, 2005

Allan Griebenow
Chief Executive Officer
Axcess International, Inc.
3208Commander Drive
Carrollton, TX  75006

Re:  Axcess International, Inc.
   Registration Statement on Form SB-2
   Filed August 19, 2005
   File No. 333-127685

   Form 10-KSB for the year ended December 31, 2004
   Forms 10-QSB for the periods ended March 31 and June 30, 2005
   File No. 0-11933

Dear Mr. Griebenow:

      We have limited our review of your filing to the disclosure
controls and procedures in your periodic filings 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 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 for the year ended December 31, 2004

Disclosure Controls and Procedures
1. Your conclusion that your disclosure controls and procedures
are
effective "in timely alerting management to material information
relating to us required to be included in our period SEC filings"
is
significantly more limited than what is called for under Rule13a-
15(e) of the Exchange Act.  Similarly narrow language is included
in
the above-cited Forms 10-QSB. The rule requires, among other
matters,
that the disclosure controls and procedures be designed "to ensure
that information required to be disclosed by the issuer in the
reports that it files or submits under the Act . . . is recorded,
processed, summarized and reported, within the time periods
specified
in the Commission`s rules and forms" and to ensure that
"information
required to be disclosed by an issuer . . . is accumulated and
communicated to the issuer`s management . . . as appropriate to
allow
timely decisions regarding required disclosure."  Please confirm,
if
true, that your disclosure controls and procedures for the
relevant
periods met all of the requirements of this section and that you
will
conform your disclosure in future filings.
2. You state in the Form 10-KSB and subsequent quarterly reports
that
there have been "no significant changes" in your internal controls
"that could significantly affect internal controls subsequent to
the
date [you] carried out [y]our evaluation."  Please note that Item
308(c) of Regulation S-B requires disclosure of any change in the
registrant`s internal control over financial reporting that
occurred
during the registrant`s last fiscal quarter that has materially
affected, or is reasonably likely to materially affect, the
registrant`s internal control over financial reporting.  Please
confirm, if true, that you met this standard and that you will
conform your disclosure to the requirements of Item 308(c) in
future
filings.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment 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.

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

?	the company may not assert staff comments and the declaration
of
effectiveness 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 connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rule 461 regarding requesting
acceleration of a registration statement.  Please allow adequate
time
after the filing of any amendment for further review before
submitting a request for acceleration.  Please provide this
request
at least two business days in advance of the requested effective
date.

      Any questions should be directed to Maryse Mills-Apenteng at
(202) 551-3457 or, in her absence, Anne Nguyen, Special Counsel,
at
(202)-551-3611.  If you still require further assistance, please
contact the undersigned at 202-551-3735.

								Sincerely,

      			Barbara C. Jacobs
      			Assistant Director

cc:  	Via facsimile:  214-712-4402
	Craig G. Ongley, Esq.
      Vial, Hamilton, Koch & Knox, LLP

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Allan Griebenow
Axcess International, Inc.
September 13, 2005
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