SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 3561

							August 16, 2005

Harmon Hardy
Chief Executive Officer
Stelax Industries Ltd.
5515 Meadow Crest Drive
Dallas, TX  75229

	RE:	Stelax Industries Ltd.
		Item 4.01 Form 8-K filed February 7, 2005
		File No. 0-18052

Dear Mr. Hardy:

          We have reviewed your 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 comments are inapplicable or a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.

          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 any other aspect
of
our review.  Feel free to contact us at the telephone numbers
listed
at the end of this letter.
1. We do not believe the statement that you mutually agreed to
engage
another accounting firm or that you "replaced" Deloitte & Touche
satisfies the requirements of Item 304(a)(1)(i) of Regulation S-X.
Please revise to state if you dismissed Deloitte or if they
resigned
or declined to stand for re-election.  You may also want to revise
the language in sub-paragraph (e) of your disclosures where you
state
you terminated Deloitte.
2. You state in subparagraph (f) you state that you have included
a
letter from the former accountants as Exhibit 16.  The document
filed
with the Commission did not contain Exhibit 16.  Please revise to
include the appropriate Exhibit 16 letter.
3. You have called Deloitte & Touche "the Accountant."  Please
consider revising to call them the "former accountants" or simply
Deloitte.  Since the newly engaged auditors are also
"accountants,"
readers may be confused.  It is also noted that in sub-paragraph
(a)
you refer to Deloitte as "auditors."

Harmon Hardy
Stelax Industries Ltd.
August 16, 2005
Page 2

4. In the first paragraph you state that you asked the former
accountants to provide a letter stating if they had any material
disagreements with the statements made in the Item 4.01 filing.
Please revise to delete the word "material."  The former
accountants`
letter should discuss any and all disagreement with the
disclosures.
5. Please revise the first sentence of sub-paragraph (a) of
management representations to use the term "were" as opposed to
"was"
since you are referring to multiple reports.  Likewise, the second
sentence should clarify that both of the last two reports were
modified to express substantial doubt, if true.  Please revise.

      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
disclosures 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 this action 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.

	The amendment requested above should be filed within five
business days from the date of this letter or we should be advised
by
that date when it will be filed.  Please file your response to
these
comments as an EDGAR correspondence file at the same time as you
file
the Form 8-K/A.  Any questions regarding the above should be
directed
to Robert Burnett at (202) 551-3330, or in his absence, to Robert
Benton at (202) 551-3804.

							Sincerely,

							Michael Moran
						            Accounting Branch Chief

??

??

??

??

</TEXT>
</DOCUMENT>