SecProbe.io

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      July 12, 2005

Mail Stop 4561

VIA U.S. MAIL AND FAX 1-732-362-5005

Mr. Dennis Mouras
Chief Financial Officer
Careadvantage, Inc.
485-C Route 1 South
Iselin, New Jersey  08830

RE:	Careadvantage, Inc.
Form 10-KSB for the year ended December 31, 2004
File no. 0-26168
Form 10-QSB for the quarter ended March 31, 2005
File no. 0-26168

Dear Mr. Mouras:

We have reviewed the above referenced filings and have the
following
comments.  We have limited our review to only your financial
statements and related disclosures and will make no further review
of
your documents.  In our comments, we may ask you to provide us
with
information so we may better understand your disclosure.  Please
be
as detailed as necessary in your explanation.  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 on any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-KSB for the fiscal year ended December 31, 2004

Note B - Summary of Significant Accounting Policies [2] Revenue
Recognition, page F-8

1. We note that your Consolidated Statements of Operations contain
`net service revenue`, which includes fee for service, per member
per
month or a combination of both.  Tell us what net amounts are
included in your net service revenue, and your basis in GAAP for
netting certain costs against revenue.  In addition, please advise
us
how you account for revenues derived from the license of
RPNavigator.

Note E - Stockholder`s Equity [3] Settlement with Horizon BCBSNJ,
page F-13

2. We note that you entered into a Settlement Agreement with
Horizon
BCBSNJ and received cash and a return of 53,394,820 shares of your
common stock in settlement.  Tell us how you ascribed a value of
$262,000 to these shares as fair market value considering that on
October 1, 2004, the fair market value was $0.01 per common share.
Also, tell us what the receivable of $762,000 recorded in fiscal
year
2003 related to.

Note H - Adjustment to Estimated Operating Leases Liability and
Write
Down of Leasehold Improvements, page F-15

3. We note that you recorded costs associated with the termination
of
certain operating leases which includes your lease in Iselin, NJ.
Tell us how you complied with paragraph 16 in determining the
cease-
use date and valuing the liability.

*    *    *    *

As appropriate, please respond to these comments within 10
business
days or tell us when you will provide us with a response.  Please
file your response on EDGAR.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings 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
disclosure in the filings;

* 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

* 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.

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 our review of your filings or in response
to
our comments on your filings.

You may contact Kelly McCusker, Staff Accountant, at (202) 551-
3433
or the undersigned at (202) 551-3413 if you have questions.

						Sincerely,

      Cicely D. Luckey
      Branch Chief

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Mr. Dennis Mouras
Careadvantage, Inc.
July 12, 2005
Page 1

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