SecProbe.io

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                       [LETTERHEAD OF BARITZ & COLMAN LLP]

                                                 June 15, 2005

VIA FACSIMILE (202/772-9205) AND REGULAR MAIL

Larry Spirgel, Assistant Director
United States Securities and Exchange Commission
100 F. Street, N.E.
Washington, DC 20549

      Re    Spantel Communications, Inc.
            ----------------------------
            Form 10KSB for Fiscal Year Ended December 31, 2004
            Form 10QSB for Fiscal Quarter Ended March 31, 2005

Dear Mr. Spirgel:

      We represent Spantel Communications, Inc. ("Spantel", or the "Company")
and in connection with your letter dated June 1, 2005, we respond on its behalf
as follows. Unless indicated to the contrary, the responses contained herein
correspond to the numbered paragraphs of your letter.

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

1. On January 5, 2005, we have been advised that a representative of the Company
spoke by telephone with a representative of the Securities and Exchange
Commission (the "SEC") regarding this issue. At that time, the Company was
advised by the SEC that the accounting firm it utilizes must be registered with
the Public Company Oversight Accounting Board (the "PCOAB") and that it must be
appropriately credentialed; that is, if this entity performs the audit function
for other SEC issuers or a domestic SEC client every year, it qualifies as being
appropriately credentialed. Spantel's annual audit was conducted by members of
the international accounting association of MSI Legal & Accounting Network,
formerly McIntyre Strater International ("MSI"), and in this regard, desired to
remain within this network as all of its operations are located in Spain. The
public accounting firm in Canada, Staley, Okada & Partners, is registered with
the PCOAB and, we understand, appropriately credentialed. This entity audits
other SEC clients and while they are located in Vancouver, Canada, it is our
understanding that substantially all of their partners are certified public
accountants registered and practicing in Canada as well as various states of the
United States. It is also our understanding that the managing partner of the
Canadian firm is also a member of the American Institute of Certified Public
Accountants.

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Larry Spirgel, Assistant Director
United States Securities and Exchange Commission
June 15, 2005 - Page 2

2. The majority of the audit work is completed in Spain by an entity known as
Audalia, which is the MSI affiliate located in Madrid, Spain. The actual audit
work is conducted under the direct supervision of Staley, Okada, Spantel's
primary auditors in Canada. The designated principals at Staley, Okada
responsible for the Spantel audit in fact travel to Spain and work directly with
Audalia during the performance of the audit procedures. It is our understanding
that Audalia is also registered with the PCOAB as required, as this entity in
fact directly participates in Spantel's audit.

Item 8A. Controls and Procedures and Item 3. Controls and Procedures
--------------------------------------------------------------------

3. Spantel's Form 10-QSB has been revised. Form 10-QSB/A for the Quarter Ended
March 31, 2005 was filed via EDGAR on June 15, 2005 to clarify that management's
evaluation of disclosure controls and procedures was as of the end of the
quarter covered by the report.

4. Spantel's Form 10KSB and 10-QSB have been revised to disclose that there were
no changes in internal controls over financial reporting that have materially
affected, or are reasonably likely to materially affect, its internal controls
over financial reporting. Form 10-KSB/A for the Year Ended December 31, 2004 and
Form 10-QSB/A for the Quarter Ended March 31, 2005 were filed via EDGAR on June
15, 2005 to reflect the foregoing.

Exhibits 31.1 & 31.2
--------------------

5. Spantel's Form 10KSB and 10-QSB have been revised with corrected
certifications. Form 10-KSB/A for the Year Ended December 31, 2004 and Form
10-QSB/A for the Quarter Ended March 31, 2005 were filed via EDGAR on June 15,
2005 to reflect the foregoing.

      In connection with the foregoing responses, we hereby advise you, as
counsel to and on behalf of Spantel, that it acknowledges:

      o     that it is responsible for the adequacy and accuracy of the
            disclosure in the filings;

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

      o     that 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.

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Larry Spirgel, Assistant Director
United States Securities and Exchange Commission
June 15, 2005 - Page 3

      If the staff requires hard copies of each of the EDGAR filed documents
referenced herein, we will provide same under separate cover. Further, if the
staff requires any additional or clarifying information, please do not hesitate
to contact the undersigned directly.

      Thank you for the opportunity to provide this response.

                                                 Sincerely,

                                                 /s/ Neil S. Baritz

                                                 Neil S. Baritz

cc:      Cesar Martinez
         Kenneth Scott
         Robert Yurglich

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