SecProbe.io

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                                   March 20, 2005

Mr. John Cash
Accounting Branch Chief
Division of Corporation Finance
US Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.   20549

Dear Mr. Cash:

In response to your Letter of Comments dated March 11, 2005, we
submit the following:

Item 2.)  We will make sure to use the Commission File number 1-
31643 on the cover page of all of our future filings.

Item 3.)  We elected a New York based firm to audit the financial
statements of our company because at the time we selected Sheft
Kahn and Company LLP (actually their predecessor firm "Stuart Kahn
& Company") we were actually based out of New York and one of our
Directors was familiar with the quality of work, years of SEC
experience and fine reputation of the firm.  Upon moving to NJ, we
saw no reason to change accounting firms since the proximity of
New York firms is very often closer than many New Jersey based
firms and there was apparently no advantage to having a New Jersey
based independent accountant.

The audit is currently performed partially in New Jersey.  There
are several warehouse locations outside of New Jersey that the
auditors visit and much of the work is done at the auditors'
office in New York from documents faxed, emailed, delivered, or
taken from our office to theirs.  The operations and most of the
assets of our company are physically located in New Jersey;
however, we do have substantial inventory located outside of New
Jersey.

We have met the requirements of Rule 2-01(a) by reviewing our
auditors' peer review reports and ascertaining (in compliance with
Reg. Sect 210.2-01 (a)) that they are in fact duly registered and
in good standing in the State of New York (their place of
residence and principal office).  We also obtain a letter (in
compliance to Reg. Sect 210.2-01(b)) from the auditors to our
Audit Committee stating that they are in fact independent within
the meaning of the Securities Acts administered by the Securities
and Exchange Commission.

<PAGE>

We understand that the State of New Jersey allows audits of New
Jersey companies to be performed by accountants who are licensed
by other states.  We have been informed by our auditors, KGS LLP
(formerly of Sheft Kahn & Company LLP) that they are in the
process of having their newly formed company registered with the
State of New Jersey, and that they will be registered shortly.

Item 4.) We will make sure to include, in our second quarter 10Q,
the voting results of the annual meeting, scheduled to be held in
June 2005.

Item 5.) Regarding Item 6. Selected Financial Data, page 10, we
felt that in accordance with Item 301 it was appropriate to
include the "Special Charges" to "enhance an understanding of" the
financial condition and results of operations for the years
presented.  However, we will revise all of our future filing to
remove the information from the presentation in accordance with
your guidance.

Item 6.) We will also revise our future filings to reflect any
cash dividends declared per share in each period.

Item 7.) Attached is our revised Management's Discussion and
Analysis which incorporates the additional information and
discussions suggested in your letter.

(a)  We have added that the revenues increased with the increased
     sales of the Mega-T appetite suppressant production and the
     introduction of Mega -T chewing gum.
(b)  We have also added that the acquisition agreement by CVS to
     acquire Eckerd caused revenues to decrease by $1,500,000 from the
     prior year.
(c)  The discussion of prospective matters that may affect the
     Company's business was added advising that the Company makes every
     effort to control its cost of manufacturing and has had no
     substantial cost increases.
(d)  The Company focused on short-term securities in all
     investments.  The short-term was decided to protect the valuations
     should interest rates rise as anticipated.  The yield was reduced
     accordingly.  The Company invested in only investment grade
     commercial paper thus reducing the degree of risk.

Item 8.) Below is our revised chart of our obligations showing the
amount of open purchase orders as of November 30, 2004.

Contractual Obligations

     The following table sets forth the contractual obligations in
total for each year of the next five years as at November 30,
2004.  Such obligations include the current lease for the
Company's premises, written employment contracts and License
Agreements.

<PAGE>

                       2005     2006       2007      2008      2009
Lease on Premises (1)449,376   449,376   449,376   449,376   449,376
Royalty Expense   (2)606,000   606,000   606,000   606,000   606,000
Employment
  Contracts (3)    2,194,772 2,294,959 2,401,156 1,988,726 2,108,049
Open Purchase
  Orders           4,495,510
Total Contractual
   Obligations     7,745,658 3,350,335 3,456,532 3,044,102 3,163,425

Item 9.) We apologize for the oversight.  Drew Edell was
previously a director, but as a result of the Sarbanes-Oxley Act
and the regulations of the American Stock Exchange, he voluntarily
resigned as a director in June 2004.  He was replaced by an
independent director, Dr. Gio Batta Gori.  Inadvertently, his
directorship was not deleted from Item 10 nor was the title
removed from his name on the signature page.  The errors will be
corrected in the amended 10K.

Item 10.) We will make sure to include in all future filings all
significant related party transactions, such as the repurchase of
common stock shares from David Edell and Ira W. Berman, in a note
to the financial statements.

Item 11.)  The Company does not have any contractual agreements
with any suppliers and/or principal customers.  It does have
agreements with customers relating to co-operative advertising,
damaged products returns and normal discounts and allowances.

The only Licensee Agreement filed was with Allegheny Pharmacal
because of the impact that the License had on the Company's
business, the initial upfront cost ($1,500,000) in 1986.  All of
the other Licenses did not require any significant upfront cost.
Inasmuch as the company did not make any major upfront
investments, the Company is free to terminate the Licenses at any
time.  There are no required royalty payments except to maintain
the License.  The Company also prefers to keep the terms
confidential.

Item 12.) i.) The disparity stems from the fact that certain
shareholders "paid" for their exercise of stock options (138,000)
by surrendering shares of stock (8,758) already owned equal in
value to the exercise price.  Therefore, the net effect on the
issuance of common stock was reduced. The issuance was then
adjusted to reflect the effect of the 2% stock dividend.

        ii) The $995,440 listed as dividends declared in the
Consolidated Statement of Shareholders' Equity, page 6, refers
only to the cash dividend declared.  The stock dividend is
reflected in the revised number of Common Stock Shares shown
throughout the statement.

       iii) The number of shares issued pursuant to the stock
dividend was 138,108.   The amount of cash dividends paid during
fiscal 2004 was $891,131 representing  $379,117of dividends
declared in Fiscal 2003 and paid in 2004 and $512,014 of cash
dividends declared and paid in fiscal 2004.  The amount of cash
dividends declared in fiscal 2004 but not paid until fiscal 2005
was $483,426.  The cash dividends of $512,014 paid in June 2004
(Fiscal 2004) and the cash dividends of $483,426 paid in December
2004 (Fiscal 2005) equals the amount of Dividends Declared shown
as a reduction of Retained Earnings in Fiscal 2004 on the
Consolidated Statements of Shareholders' Equity.  The Stock
dividend declared is reflected in the 2% proportionate increase in
all per share amounts shown on the Statement of Shareholders'
Equity.

<PAGE>

Item 13.)  The pertinent rights and privileges of our Class A
Common Stock are identical to the other Common Stock with the
exception that the Class A shareholders have the right to elect 4
members to the Board of Directors whereas the Common shareholders
can only elect 3 members.

Item 14.) It is impossible to ascertain when exactly the benefits
of advertising expenditures are realized but it is logical to
assume that the benefits overlap more than one interim period
especially since some of the advertising can run right up to the
last day of a particular period with no opportunity to reap the
benefits from it until the next period.  Although, in accordance
with GAAP standards, we expense all of our advertising
expenditures within the Fiscal year they are incurred, we attempt
to give a more accurate picture of the results of our operations
by charging them against income equally through the year (in
accordance with the guidelines of APB 28 and SOP 93-7) rather than
distort any one periods results of operations by charging it with
a disproportionate amount of advertising expense. Quarterly
results could then be misleading and confusing to the public in
ascertaining how the Company is performing during the year.

Item 15.) Our Trademarks consist of various brand names and we
have found that the nature of our business is such that we must
keep updating our products and revising our Branding to keep up
with current market trends. Therefore, most of our Trademarks
become obsolete or devalued after several years. Since we
anticipate that the Trademarks will lose some value as new
competitive products are introduced into the market we amortize
them over 15 years to reflect that gradual decrease in value.  We
use 17 years for any patents which we have on any of the product
formulations to coincide with the legal life of the patent.

Item 16.) The average expected life of the stock options used to
estimate the fair value of the options was based on the options
issued during Fiscal 2004.  We apologize for the misprint. The
average life was 5 years.  We had several people proof read the
10K and the number had been changed to "5 years" as had the
removal of the term "director" in item nine.  Apparently, the
final corrected version was not transmitted via EDGAR.  The
volatility was calculated by using a logarithm of the average
fluctuation of the stock price over the last 36 months.

Item 17.) There is no proforma effect of recognizing compensation
expense in accordance with FAS123 for Fiscal 2003 and 2002 because
no new stock options were granted during those periods. In Fiscal
2004, the proforma effect is shown since there were options
granted during the year.

Item 18.) The repriced or extended terms of any option grants have
been reflected in any calculations of EPS and Weighted Average
Shares.

Item 19.) Attached is the revised disclosure in Footnote #9 in
accordance with paragraphs 47 and 48 of SFAS No. 123.

Item 20.)  Our total royalty costs by licensor for each of Fiscal
years 2002, 2003, and 2004 are as follows:

<PAGE>

                      2004            2003           2002
"A"                 $91,968         $52,033        $74,711
"B"                 109,035         427,419        672,538
"C"                   8,369           1,906          3,850
"D"                    (910)         12,555          2,654
"E"                   1,829           3,973              0
"F"                  69,714          40,782              0
"G"                     186             143            278
"H"                  68,935               0              0
"I"                  86,611         143,616         70,362

Total              $435,737        $682,427       $824,393

Item 21.)  The information set forth in Item 3 Legal Proceedings
sets forth the fact that there were originally 13 cases filed in
which the Company was named along with other defendants.  Eleven
cases have been dismissed with prejudice.  These cases cannot be
legally reinstated.  The one case in Philadelphia in which one of
the defendants filed for bankruptcy has been delayed.  The court
is rendering a decision on our motion to dismiss.  We agree with
independent counsel that because under the decision in Seattle,
unless a plaintiff ingested a product with PPA within three days
of a stroke, there can be no causation to prove that a product
caused the stroke.  We feel that the case should be dismissed
inasmuch as plaintiff at the deposition deposed that she took our
product months before the stroke.

The remaining case in Louisiana is fully insured to the extent of
$5,000,000.  After reviewing the plaintiff's medical records, it
does not appear that there is ongoing significant medical problems
that would cause a jury to render a substantial judgment.  Counsel
evidently in discussing the matter with Phoenix Insurance Company
has not made any substantial efforts to settle the case which we
have been led to believe could be settled for under $250,000.

We do not believe that any further litigations would be ensuing
because the Statute of Limitations throughout the country provided
that the case must be instituted within three to four years within
the time frame in which a plaintiff had constructive notice of the
product that proximately caused a stroke.  The FDA put out a news
release nationally in October 2000.  We included the last
sentence,  "However...", because we believe it is the normal
boiler plate exculpation clause generally used when discussing
litigation."

Item 22.) We considered recognizing the total lease expense on a
straight line basis over the expected term and decided that the
difference was immaterial to the financial statements.  Based on
the fact that we realize there is a reasonable possibility that
the lease will be renegotiated prior to its term and the straight
line method might not ultimately reflect the true expense anyway
we felt that expensing what we currently incur most accurately
reflects the results of operations for the current period.

Item 23.)  The amount of options that were excluded from the
calculation because of their anti-dilution effect were 0, 0, and
50,000 for fiscal 2002, 2003 and 2004, respectively.

<PAGE>

Item 24.) We apologize again, although this was also corrected
prior to the EDGAR filing, apparently the penultimate draft was
accidentally used for the EDGAR transmission rather than the
"final draft".  The chronological order is not reversed, the items
were simply not updated from the 2003/2002 amounts to the
2004/2003 amounts. The number you attempted to reconcile with the
2004 numbers was in fact the 2002 number. We have corrected the
presentation in the amended 10K.

Item 25.)  Specific reserves of certain individually large
receivables no longer exist because they were reduced due to the
actual write-off or collection of the specific amount thereby
reducing the reserves disproportionately.

We hope this response adequately answers all of the questions you
had regarding our filing.  If additional clarification or
disclosures are necessary please notify us and we will gladly
provide the necessary data. We understand that 1) we are
responsible for the adequacy and accuracy of the disclosure in our
filings, 2) 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  3) 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.

Very truly yours,

Mr. John Bingman
Chief Financial Officer

<PAGE>

Item 7.  MANAGEMENT'S DISCUSSION AND ANALYSIS OF
      FINANCIAL CONDITION AND RESULTS OF OPERATIONS - AMENDED

      Except  for  historical information contained herein,  this
"Management's Discussion and Analysis of Financial Condition  and
Results   of  Operations"  contains  forward-looking  statements.
These   statements   involve  known   and   unknown   risks   and
uncertainties