SecProbe.io

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Mail Stop 3561

								November 8, 2005

BY U.S. MAIL and FACSIMILE  [ (248) 489 - 9334 ]

Mr. Brian T. Donnelly
  President and Chief Operating Officer
AJAY SPORTS, INC.
37735 Enterprise Court, Suite 600
Farmington Hills, Michigan  48331

	Re:	Ajay Sports, Inc.
		Item 4.01 Form 8-K
		Filed October 26, 2005
		File No. 0-18204

Dear Mr. Donnelly:

	We have reviewed the above referenced filings for compliance
with the requirements with respect to the Item 4.01 disclosures of
the Form 8-K.  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.

	Pursuant to Rule 101(a)(3) of Regulation S-T, your response
should be submitted via EDGAR, under the label "corresp," within
five
business days of the date of this letter.  Please note that if you
require longer than five business days to respond, you should
contact
the staff immediately to request additional time.  An amendment to
the Item 4.01 Form 8-K should be filed immediately.

	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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Brian T. Donnelly
Ajay Sports, Inc.
November 8, 2005
Page 2

Item 4.01 of Form 8-K

1. Revise the first paragraph to specifically disclose whether the
former independent accountants, J.L. Stephan, Co. PC CPAs,
resigned,
declined to stand for re-election or was dismissed and the date.
See
Item 304(a)(1)(i) of Regulation S-B.

2. Please expand the fourth paragraph to disclose whether there
were
any disagreements or reportable events with J.L. Stephan, Co. PC
CPAs
for the fiscal years ended December 31, 2001 and December 31, 2002
and the subsequent period through the effective date of change in
certifying independent accountant.

3. In the amended Item 4.01 Form 8-K please provide the required
Exhibit 16.1 letter from the former accountants, J.L. Stephan, Co.
PC
CPAs, indicating whether or not they agree with your revised
disclosures.  See Item 304(a)(3) of Regulation S-B.

Other

	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
Exchange Act of 1934 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.

	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
disclosure 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 staff comments 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 our review of your filing or in
response to our comments on your filing.

Brian T. Donnelly
Ajay Sports, Inc.
November 8, 2005
Page 3

Closing

	You may contact the undersigned below at (202) 551-3328 if
you
have questions regarding the above matters.

Sincerely,

								Beverly A. Singleton
								Staff Accountant

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(..continued)

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