SecProbe.io

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Mail Stop 0308

							March 31, 2005

Morton Berger
Chief Financial Officer
Safari Associates Inc.
13 Eastbourne Drive
Chestnut Ridge, NY  10977

	RE:	Safari Associates Inc.
		Item 4.01 Form 8-K filed February 23, 2005
            	File No. 0-30215

Dear Mr. Berger:

          We have reviewed the above referenced filing and have
the
following comments.  We welcome any questions you may have about
our
comments.  Feel free to contact us at the telephone numbers listed
at
the end of this letter.

1. Please amend your Form 8-K to include a letter from your former
accountant indicating whether or not he agrees with the
disclosures
in the Form 8-K.  See Item 304(a)(3) of Regulation S-B.

2. The last sentence of the fifth paragraph states that the
resignation of the prior independent accountants was reported in a
Form 8-K dated December 31, 2004, as amended.  Our records do not
reflect the filing of a Form 8-K dated December 31, 2004.  Please
tell us the name of the prior accountant you are referring to, and
correct the disclosure of the prior report you are referring to.
We
may have additional comment.

3. Your Form 10-KSB/A for the year ended December 31, 2003, filed
on
January 3, 2005 does not include an audit report for the year
ended
December 31, 2002.  Please tell us what your plans are to have
2002
audited by a registered independent accountant.  We may have
further
comment.

Morton Berger
Safari Associates Inc.
March 31, 2005
Page 2

      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.  The amendment should include an
appropriate letter from your former accountants indicating that
they
have read the Form 8-K/A.  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 me at (202) 942-1809, or in my absence, to Robert Benton at
(202)
942-1811.

							Sincerely,

							Robert Burnett
						            Staff Accountant

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