SecProbe.io

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Mail Stop 0306

April 1, 2005

By U.S. Mail and Facsimile to (407) 321-3208

Mr. Wayne Thaw
Chief Executive and Chief Financial Officer
TNR Technical, Inc.
301 Central Park Drive
Sanford, Florida 32771

	RE: 	TNR Technical, Inc
		Form 10-K / A for the year ended July 31, 2004

Dear Mr. Thaw,

      We have reviewed your response letter dated March 22, 2005
and
have the following additional comment. Where indicated, we think
you
should revise your document in response to this comment.  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
or may not 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
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

From 10-K / A for the fiscal year ended July 31, 2004

Item 9(a) Controls and Procedures and Exhibit 31 Certification

1. We note your response to our prior comments 9 - 12.  It is
unclear
as to why you believe that these changes would be immaterial.
Additionally please note that you are required to file currently
dated officer certifications in the proper form.  The required
Exhibit 31 certifications must be in the exact form prescribed;
the
wording of the required certifications may not be changed in any
respect, except for the modifications temporarily permitted to be
made to the fourth paragraph of the certification required to be
filed as Exhibit 31 pursuant to Part III.E of Release No. 8238.
Accordingly, please file an amendment to your Form 10-K that
includes
the entire filing together with the certifications of each of your
current CEO  / CFO in the form currently set forth in Item
601(b)(31)
of Regulation S-K.

*	*	*	*

	As appropriate, please amend your July 31, 2004 Form 10-K and
respond to this comment within 10 business days or tell us when
you
will provide us with a response. You may wish to provide us with
marked copies of the amendment to expedite our review.  Please
furnish a cover letter with your amendment that keys your
responses
to our comments and provides any requested supplemental
information.
Please file your cover letter on EDGAR.  Please understand that we
may have additional comments after reviewing your responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
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 Eric Atallah, Staff Accountant at (202) 824-
5266
or me at (202) 942-2861 regarding comments on the financial
statements and related matters.  In this regard, do not hesitate
to
contact Daniel Gordon, Branch Chief, at (202) 942-2813.

      								  Sincerely,

								  Kate Tillan
								  Reviewing Accountant
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Mr. Wayne Thaw
TNR Technical, Inc
April 1, 2005
Page 2

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