SecProbe.io

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Mail Stop 3561

							October 13, 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 as amended
September 19, 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. In our comment letter dated August 16, 2005 we requested you to
provide certain representations, in writing.  We do not see where
you
have provided these representations.  Please file EDGAR
correspondence with the requested information.  For your
convenience
this letter repeats the representations we previously requested.
2. In comment number one from our August 16, 2005 comment letter,
we
requested you use the term "dismissed" rather than "replaced."
Please revise to use the term "dismissed" if Deloitte did not
resign
or decline to stand for reelection.
3. Please revise to disclose the date you engaged Killman, Murell
&
Co.  Since the engagement of new auditors is an event separate
from
the dismissal of Deloitte, you may want to provide this disclosure
in
a separate paragraph.

Harmon Hardy
Stelax Industries Ltd.
October 13, 2005
Page 2

4. Item 304(a)(3) of Regulation S-K requires you to request a
letter
from the former accountants stating whether they agree with the
statements made in the filing.  We believe that your disclosure in
the first paragraph of the amendment filed September 19, 2005,
limits
the scope of the letter required from your former accountant.  For
example, the filing should discuss any disagreements with Deloitte
through February 1, 2005, not just those in connection with the
last
two fiscal years on which Deloitte opined.  It also appears that
sub-
paragraph (f) of your disclosure covers the same information.
Please
revise to delete the duplicative information or make the
disclosures
consistent.
5. It appears that sub-paragraph (a) of managements`
representations
relates to reports issued by Deloitte.  It is not clear why you
refer
to disputes in this paragraph or how you define "disputes" as
opposed
to disagreements.  Please revise to provide the information
required
by Item 304(a)(1)(ii) of Regulation S-K in a clear manner.  If you
believe no revision is necessary, please support your position.
6. In your amendment filed September 19, 2005, you stated you
would
file the required by Item 304(a)(3) of Regulation S-K letter when
received.  Please tell us if you have received the letter.  If you
have not received the letter, please tell us what efforts you have
made in this regard.  Your response should include the dates,
addresses and names of any people you have attempted to contact,
and
any other information you have learned in this process.  We may
have
additional comment.

      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.

Harmon Hardy
Stelax Industries Ltd.
October 13, 2005
Page 3

	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 me at
(202) 551-3841.

							Sincerely,

							Michael Moran
						            Accounting Branch Chief

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