SecProbe.io

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                               BARITZ & COLMAN LLP
                     150 East Palmetto Park Road, Suite 750
                            Boca Raton, Florida 33432
                            (561) 750-0910 telephone
                            (561) 750-5045 facsimile

                                 August 5, 2005

VIA EDGAR, 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 July 14, 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.

Response to Staff Comment Letter Dated June 1, 2005

         1. With respect to Item 1, please be advised that none of the Company's
books and records is maintained in Canada and further, that none of its
officers/directors or management reside in Canada. For your information, the
Company has given serious consideration to changing its audit firm to the
Spanish accounting firm that currently performs its audit in Spain and is
inclined to formalizing the change. Your direction in this matter would be
greatly appreciated.

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. With respect to Item 2, we have been advised by management that a
considerable amount of judgment is required when assessing the ultimate
realization of receivables, including assessing the probability of collection
and the current credit-worthiness of customers. The Company establishes an
allowance for doubtful accounts based on a qualitative and quantitative review
of credit profiles of customers, contractual terms and conditions, current
economic trends and historical payments. Management has further advised us that
the Company assesses the allowance for doubtful accounts each period.
Historically, the accounts receivable and revenue reserves have been sufficient
to absorb any credits and bad debt write-offs recorded in subsequent periods.
The Company will provide an analysis of the allowance for doubtful accounts
receivable in future filings.

<PAGE>
Larry Spirgel, Assistant Director
United States Securities and Exchange Commission
August 5, 2005 - Page 2

Revenues

         3. In response to Item 3, management has advised us that Spantel
receives money in advance from its customers making prepayments in what are
known as telephone shops, which it records as deferred revenue. As services are
provided (telephone minutes used), the revenue is recognized and the
corresponding liability (deferred revenue) is reduced.

         For the year ended December 31, 2004 and the quarter ended March 31,
2005, the amount of revenue generated was $2,323,021and $487,227 respectively.

         Telephone cards are sold only to distributors. Revenue is recognized
when sales of cards are made to the distributor and collection is probable.

         For the year ended December 31, 2004 and the quarter ended March 31,
2005, the amount of revenue generated from the sale of telephone cards was
$605,240 and $307,829, respectively.

Note 1 - Organization, Operations and Significant Accounting Policies

Deferred Subscriber Acquisition Costs

         4. In response to Item 4, we have been advised by management that the
Company utilizes the services of independent agencies to acquire subscribers. As
an incentive to obtain new subscribers, the Company had paid the agencies
advances on commissions to be earned by them in the future. The contracts with
such agencies called for commissions to be earned at a rate of between 5%-8% of
the minutes used in the future by the customers acquired. The deferred
subscriber acquisition costs for each period consists of funds advanced to these
independent agencies less the commissions earned by such agencies. In essence,
the Company treats these items as prepaid costs.

         5. In response to Item 5, we have been advised by management that the
Company classifies as current assets the portion of the deferred subscriber
acquisition costs that it estimates to be earned by the agencies in the ensuing
one-year period, while the remainder is classified as long term.

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Larry Spirgel, Assistant Director
United States Securities and Exchange Commission
August 5, 2005 - Page 3

         Management has further advised us that related party transactions have
already been presented in the Balance Sheet and Statement of Cash Flows. The
Company has revised its presentation of related party transactions in the
Statement of Operations.

Cash Equivalents

         6. In response to Item 6, we have been advised by the Company that it
has revised its financial statement presentation to identify cash and cash items
which are restricted as to withdrawal or usage.

         Thank you for the opportunity to provide this response. 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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