SecProbe.io

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ATTORNEYS

November 2, 2005

  Securities and
  Exchange Commission

  450 Fifth
  Street, N.W.

  Washington, D.C.
  20549-0406

  Attention:

  Stephen
  Krikorian

  Accounting
  Branch Chief

  Re:

  NWH,
  Inc,

  Form 10-K
  For the Fiscal Year Ended October 31, 2004

  Form 10-Q
  For the Fiscal Quarter Ended January 31, 2005

  Form 10-Q
  For the Fiscal Quarter Ended April 30, 2005

  Form 10-Q
  For the Fiscal Quarter Ended July 31, 2005

  File
  No.: 000-26598

Greetings:

We are
in receipt of the Commission’s letter of comment, dated October 25, 2005,
and, on behalf of NWH, Inc. (“NWH” or the “Company”), have the responses
set forth below.

Form 10-Q for the Quarterly Period Ended
April 30, 2005

Item 2. Management’s Discussion and Analysis
of Financial Condition and Results of Operations

Use of Non-GAAP Financial Measures, page 22

As stated in our previous
response, the chief operating decision maker (CODM) changed to using the
current measure of ENS’ segment profit (loss) in the quarter ended July 31,
2005 due to the repayment of all debt to outside parties and the related
elimination of interest expense in May 2005 and the normalization of
depreciation and amortization expense.  The CDOM used the previously
disclosed measure of segment profit (loss) to assess the performance of ENS and
to decide how to allocate resources for the year ended October 31, 2004
and subsequent quarters prior to the quarter ended July 31, 2005.  The Company will elaborate on this
change in its next Form 10-K filed for the year ended October 31,
2005 in order to clarify the reason for the change in our segment measure.

I enclose a statement from the Company acknowledging
that:

•                  The Company is responsible for the
adequacy and accuracy of the disclosure in the filing;

•                  Commission staff comments or changes
to disclosure in response to staff comments do not foreclose the Commission
from taking and action with respect to the filing; and

•                  The Company may not assert staff
comments in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

488 Madison Avenue •
New York, N.Y. 10022 • Phone (212) 736-1000 • (212) 478-7200

Fax (212) 478-7400 • Email:
thefirm@hahnhessen.com

Please contact the undersigned at (212) 478-7250 if
you have any comments regarding the foregoing or need additional information.  We would appreciate receiving any further
comments at your earliest convenience.

  Very truly yours,

  S/JAMES KARDON

  James Kardon

  Enclosures

  cc:

  Terrence S.
  Cassidy

  McGladrey Pullen
  LLP

2

ACKNOWLEDGMENT OF NWH, INC.

I, Terrence S. Cassidy, the Chief Executive Officer of NWH, Inc.
(the “Company”), acknowledge that:

1)              I have reviewed the letter dated November 2,
2005 filed by the Company’s counsel in response to the Commission’s comment
letter dated October 25, 2005 concerning the following filings: Form 10-K
For the Fiscal Year Ended October 31, 2004, Form 10-Q For the Fiscal
Quarter Ended January 31, 2005, Form 10-Q For the Fiscal Quarter
Ended April 30, 2005, and Form 10-Q For the Fiscal Quarter Ended July 31,
2005.

2)              The Company is responsible for the adequacy
and accuracy of the disclosure in the filings; Commission staff comments or
changes to disclosure in response to staff comments do not foreclose the
Commission from taking and action with respect to the filings; and the Company
may not assert staff comments in any proceeding initiated by the Commission or
any person under the federal securities laws of the United States.

  NWH, Inc.

  Date:
  November 2, 2005

  By:

  /s/
  TERRENCE S. CASSIDY

  Terrence
  S. Cassidy

  Chief
  Executive Officer