SecProbe.io

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                       Secured Digital Application, Inc.
           11, Jalan 51A/223, 46100 Petaling Jaya , Selangor Malaysia
                    Phone: (603) 79554582 Fax (603) 79578310
                            URL: www.digitalapps.net

August 9, 2005

Mr. Larry M. Spirgel, Assistant Director
Securities and Exchange Commission
450 5th Street NW
Mail Stop 3561
Washington, D.C. 20549

Re:      Secured Digital Applications, Inc. ("SDA", or the "Company")
         Form 10-KSB for the year ended December 31, 2004
         Form 10-QSB for the quarter ended March 31, 2005
         Commission file number: 000-25658

Dear Mr. Spirgel:

This letter provides  responses to the comments contained in your letter of July
15, 2005,  regarding the Company's  Form 10-KSB for the year ended  December 31,
2004, and the Company's March 31, 2005 Form 10-QSB. These responses are numbered
in accordance with the numbered comments contained in your letter.

FORM 10-KSB FOR THE FISCAL YEAR ENDED DECEMBER 31, 2004

Consolidated Statements of Operations, page F-4
-----------------------------------------------

1.   In  previously  filed  reports,  product  sales  have not  been  considered
     material to the Company's  financial  statements.  We will comply with your
     request to  segregate  revenues  and costs of revenues of our  products and
     services in our future filings.

Note 2: Significant Accounting Policies, page F-12
--------------------------------------------------

Revenue Recognition, page F-15
------------------------------

2.   The phrase "revenue  represents the net invoiced value of goods sold" means
     revenue, net of discounts, allowances and returns. The Company's sources of
     revenues are from its Applications,  Material Handling,  and Apple Computer
     ("Gallant") businesses as follows:

     a.   Applications   revenue  is  derived  from   applications   development
          services,  services in  connection  with the  operation of a broadband
          network,  and sales of devices that utilize broadband networks as well
          as sales of biometric security products.

     b.   Material  Handling  revenue is  derived  from  services  we provide in
          connection with industrial  moving,  land  transportation  and secured
          logistics,  the sale of industrial packing and unpacking  equipment as
          well as the sale, rental and servicing of material handling equipment.

     c.   Apple Computer  revenues are derived  primarily from the sale of Apple
          Computers and related  accessories  in an  authorized  Apple Center as
          well as the supply and provision of  information  technology  products
          and services.
<PAGE>
Mr. Larry Spirgel, Assistant Director                             August 9, 2005
Securities and Exchange Commission                                        Page 2

The Company  recognizes  revenues pursuant to SAB 104 and related  authoritative
literature.  Revenues  from  services  are  recognized  when  the  services  are
provided.  Revenues from the sales of products and equipment are recognized when
the  significant  risks and rewards of  ownership  have passed to the  customer.
Factors such as customer acceptance return policies,  post shipment obligations,
warranties,  credits and  discounts,  rebates,  and price  protection or similar
privileges,  have  historically not been considered  significant and have had no
material impact on revenue recognition.

Future Company filings will reflect  additional  disclosure and clarification of
the Company's revenue recognition policies.

Note 3: Acquisition and Disposal of Subsidiaries, page F-19
-----------------------------------------------------------

3.   The Company  acquired/formed  the investments  referred to in Note 3 to the
     December 31, 2004 financial statements as follows:

     -    The Company  acquired its majority  equity  interests in AEC, ALG, ASS
          and ATG (the  "Subsidiaries")  from  AMH for  total  consideration  of
          $268,046,  of which  $119,047  was  allocated to ASS, and $148,999 was
          allocated to AEC, ALG and ATG.

     -    The Company invested $3,947 in TW upon TW's formation.

     -    The Company  acquired its equity  investments  in ATP and AEG from AMH
          for total consideration of $45,222.

     Through  December 31, 2004,  the Company paid $263,158 to AMH, of the total
     amount owed to AMH of $313,268.  As of December 31, 2004, the Company has a
     remaining  liability  of  $50,110  to AMH,  which  is  recorded  in  "other
     payables".

4.   No  goodwill  was  recognized   upon  the  Company's   acquisition  of  the
     Subsidiaries.  The  Company  sold AEC,  ALG,  ATG and TW (the  "Group")  in
     December 2004, which had an original cost of $152,946  ($148,999  allocated
     to AEC,  ALG and ATG plus  $3,947  allocated  to TW).  From the date of the
     Group's  acquisition/formation  through the disposal  date,  the  Company's
     share of losses  attributed  to the Group was  $140,644.  As a result,  the
     $131,115  gain  on  disposal  of the  Group  was  determined  based  on the
     difference  between the cash  consideration  received  of $143,417  and the
     remaining  carrying  value  of the  Company's  investment  in the  Group of
     $12,302.

Note 13: Shareholders' Equity, page F-29
----------------------------------------

5.   The Company formed SDA America,  Inc.  ("SDAA",  a non-operating,  Delaware
     Corporation)  as a  wholly-owned  subsidiary  in May 2004,  solely  for the
     purpose of  establishing a U.S based  subsidiary to facilitate the Series A
     Convertible Preferred Stock (the "Series A") Transaction.

     The Company  accounted for the issuance of the Series A as permanent equity
     in  consideration  of Emerging  Issues Task Force  (EITF)  Topic No.  D-98,
     Classification  and  Measurement  of  Redeemable  Securities.  Although the
     Company  has the  option to redeem  the  Series A, the  Series A is not (1)
     redeemable at a fixed or determinable price on a fixed or determinable date
     (2) at the option of the  holder,  or (3) upon the  occurrence  of an event
     that is not solely within the control of the issuer.

<PAGE>
Mr. Larry Spirgel, Assistant Director                             August 9, 2005
Securities and Exchange Commission                                        Page 3

     As discussed in Note 13, in November 2004,  the Company issued  warrants to
     purchase  1,300,000  shares of the Company's  common stock in consideration
     for the Series A holder agreeing to amend the Securities Purchase Agreement
     (the "SPA") to remove the listing requirement, as defined, from the SPA.

     In accounting for this transaction,  the Company  considered the provisions
     of  EITF  No.  00-18,   Accounting  Recognition  for  Certain  Transactions
     involving Equity Instruments  Granted to Other than Employees,  and whether
     the corresponding cost (of equity instruments) is an immediate expense or a
     prepaid   asset  (or  whether  the  debit   should  be   characterized   as
     contra-equity).  The  Company  determined  that the  removal of the listing
     requirement was a cost associated with the Series A issuance, and therefore
     represented a discount to the issuance (a contra-equity presentation).

     The Company  classified  the $6.5 million of  restricted  cash as a current
     asset  because  pursuant  to the SPA,  the  funds  can be used for  working
     capital purposes.

     Please note that on August 1, 2005, the Laurus Master Fund, Ltd. ("Laurus")
     converted  accrued  dividends on the Series A preferred  and pursuant to an
     agreement  between  the Company  and  Laurus,  the Series A  preferred  was
     cancelled.  The Company also redeemed its outstanding Convertible Term Note
     with  Laurus in  connection  with the winding  down of the Laurus  funding.
     These transactions were reported on Form 8-K, filed August 3, 2005.

Form 8-K Filed September 30, 2004
---------------------------------

6.   The Company made a  determination  subsequent to the filing of the Form 8-K
     filed  September  30,  2004,  that  Gallant   represented  an  individually
     insignificant   business,   and  the  aggregate   impact  of   individually
     insignificant  businesses acquired (Gallant and Asiaco) did not exceed 50%.
     Therefore, the Company determined that financial statements of Gallant (and
     Asiaco)  were not  required to be filed in an amended  Form 8-K pursuant to
     Item 310(c) of Regulation S-B.

Comments or questions  regarding the above  responses  should be directed to the
undersigned at telephone number (603) 79567026 or email p.lim@eystar.com.

Sincerely,

/s/  Patrick Soon-Hock Lim
---------------------------------------
Patrick Soon-Hock Lim
Chairman and Chief Executive Officer

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