SecProbe.io

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

Mail Stop 3561

      							July 14, 2005

Cezar Martinez
Treasurer and Chief Financial Officer
Spantel Communications, Inc
5192 10th Avenue North, Suite D
Lake Worth, FL 33463

	Re:	Spantel Communications, Inc
      Form 10-KSB for Fiscal Year Ended December 31, 2004
		Filed April 29, 2005

		Forms 10-Q for Fiscal Quarter Ended March 31, 2005
		File No. 0-25124

Dear Mr. Martinez:

We have reviewed your response to us 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.  Please be as detailed as necessary in
your explanations.  In our comments we asked you to provide us
with
information so we may better understand your disclosure.  After
reviewing this information, we may or may not 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Response to Staff Comment Letter Dated June 1, 2005

1. We note your response to our comments number 1 and 2.  Please,
respond to the following:
* Tell us if any of your books and records are maintained in
Canada
and/or do any of your officers and/or directors and/or management
reside in Canada.
* Tell us why you believe it is appropriate to continue to use a
Canadian firm, in light of the fact that you are domiciled in the
US
and you operations are conducted in Spain.
* Tell us if you have considered changing audit firms to either a
US
or a Spanish firm.

Form 10-KSB for Fiscal Year Ended December 31, 2004

Item 6.  Management`s Discussion and Analysis or Plan of
Operations

Application of Critical Accounting Policies

2. In future filings, provide your analysis of allowance for
uncollectible accounts receivable.  Refer to Item 303 (b)(i) of
Regulation S-X.

Revenues

3. We note that your revenue streams include prepayment telephone
services to phone shops and small business and sales of telephone
cards.  Tell us how you recognize revenues from such arrangements
and
quantify the amounts of revenue derived from such sources.
Further,
tell us when the service is complete with respect to such
arrangements.

Note 1 - Organization, Operations and Significant Accounting
Policies

Deferred Subscriber Acquisition Costs

4. Describe in more detail the nature of these costs.  Tell us and
refer your basis in relevant accounting literature, how you
account
for such costs.

5. Tell us how you determine the amount classified as current and
non
current asset in your Balance Sheet.

As required by Rule 4-08 (k) of Regulation S-X, revise your
presentation to identify related party transactions separately on
the
face of your Balance Sheet, Statement of Operations and Statement
of
Cash Flows.

Cash Equivalents

6. As required by Rule 5-02 of Regulation S-X, revise your
presentation to identify cash and cash items which are restricted
as
to withdrawal or usage.

*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response, and file your
correspondence via EDGAR.  Please furnish a letter that keys your
responses to our comments and provides any requested information.
Detailed letters greatly facilitate our review.  Please understand
that we may have additional comments after reviewing your
responses
to our comments.

      You may contact Nicole Holden, Staff Accountant, at (202)
551-
3374 or Carlos Pacho, Senior Assistant Chief Accountant, at (202)
551-3835 if you have questions regarding comments on the financial
statements and related matters.  Please contact me at (202) 551-
3810
with any other questions.

								Sincerely,

								Larry Spirgel
								Assistant Director

[CC: Neil S. Baritz, council]
??

??

??

??

Cezar Martinez
Spantel Communications, Inc
July 14, 2005
Page 3

</TEXT>
</DOCUMENT>