SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Mail Stop 7010

June 20, 2005

via U.S. mail and facsimile

Robert C. Sepucha
Chief Executive Officer
SPARTA, Inc.
25531 Commercentre Drive, Suite 120
Lake Forest, California  92630-8873

	Re:	SPARTA, Inc.
		Form 10-K for the fiscal year ended January 2, 2005
		Filed April 1, 2005
		File No. 0-21682

Dear Mr. Sepucha:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review  to
other
portions of your documents.  Where indicated, we think you should
revise your document in future filings 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.  In some of our
comments,
we may ask you to provide us with information so we may better
understand your disclosure.  After reviewing this information, we
may
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 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.

Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations, page 20

Results of Operations, page 21

1. We note that you present the non-GAAP measure, gross profit,
which
eliminates unallowable costs from income from operations.  In
future
filings, please ensure your disclosure of this measure is
allowable
under Item 10(e)(1)(ii)(B) of Regulation S-K.

Consolidated Balance Sheets, page 35

2. We note that you have not separately presented a separate line
item for billings in excess of costs on the face of your
consolidated
balance sheets or in your footnotes.  Please tell us where you
have
recorded this amount in your consolidated balance sheets,
including
the amount recognized for each period presented.  If you have
netted
this amount against receivables, revise in future filings to
present
such amounts separately.

Note 1 - Description of Business and Summary of Significant
Accounting Policies:  a) Description of business, page 39

3. We note that you operate your business as one reportable
segment.
We also note that your management team consists of four president
for
each sector in which you operate:  (a) Hardware Systems; (b)
Missile
Defense; (c) National Security Systems; and (d) Mission Systems.
Please tell us how you determined that these sectors are not
operating segments as defined in paragraph 10 of SFAS 131.

If you have determined that each of these sectors are operating
segments under SFAS 131 and are aggregating the four sectors into
one
reporting segment for financial statement purposes, please provide
us
with your detailed analysis of the criteria listed in paragraph 17
of
SFAS 131 that demonstrates each of the sectors meets all of the
criteria listed.  Your detailed analysis should include the
revenues,
gross profits, gross profit margins, operating profits, and
operating
profit margins, along with any other information you believe would
be
useful, for each of your operating segments for each of the three
years ended January 2, 2005 and the 3-month periods ended April 3,
2005 and 2004 to help us understand how these sectors are
economically similar.  Specifically address any differences in the
trends these financial indicators depict (e.g., if gross profit
margin is decreasing for one sector and increasing for another).

Finally, please tell us why you have not provided disclosures for
revenues from external customers for each group of similar
products
and services, at a minimum, such as the business areas discussed
in
the second to the last paragraph on page 3 of your filing:  (a)
missile defense; (b) tactical military systems; (c) network
centric
warfare; (d) space systems; and (e) hardware systems.  Refer to
paragraph 37 of SFAS 131 for additional guidance.

Note 1 - Description of Business and Summary of Significant
Accounting Policies:  c) Revenue recognition, page 39

4. In future filings, please expand your revenue recognition
policy
to address the following:
* The principle components of contract costs;
* How and when you recognize claim and unapproved change order
revenues and costs, including amount of revenue recognized, if
material, for each period presented;
* How and when you record a provision for anticipated contract
losses;
* How and when you recognize contract incentives and/or award
fees;
and
* How you recognize revenues and costs when combining and
segmenting
contracts, if applicable.
Refer to SOP 81-1 and the AICPA Audit and Accounting Guide for
Audits
of Federal Government Contractors for guidance.  In your response,
please provide us with the expanded disclosure you intend to
include
in future filings.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a letter that keys your responses to our comments
and
provides any requested supplemental information.  Detailed
response
letters greatly facilitate our review.  Please file your response
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 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 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.

      You may contact Tracey Houser, Staff Accountant, at (202)
551-
3736, Jeanne Baker, Assistant Chief Accountant, at (202) 551-3691,
or
me at (202) 551-3255, if you have questions regarding comments on
the
financial statements and related matters.

Sincerely,

Nili Shah
Accounting Branch Chief

??

??

??

??

Robert C. Sepucha
SPARTA, Inc.
June 20, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>