SecProbe.io

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                     [TARGET LOGISTICS, INC. LOGO]

March 17, 2005

VIA EDGAR AND FAX
-----------------

Mr. Michael Fay
Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, NW
Washington, DC 20549

RE:      TARGET LOGISTICS, INC. (THE "COMPANY")
         FORM 10-K FOR THE YEAR ENDED JUNE 30, 2004
         FILE NO. 0-29754

Dear Mr. Fay:

I am writing in response to your letter of February 18, 2005 regarding the above
file number. Below are responses to the comments raised.

COMMENT 1
---------
MANAGEMENT'S  DISCUSSION  AND  ANALYSIS OF  FINANCIAL  CONDITION  AND RESULTS OF
OPERATIONS, PAGE 9, RESULTS OF OPERATIONS, YEARS ENDED JUNE 30, 2004 AND 2003

All of our services are provided through our Target subsidiary  ("TLSI") and its
network of offices in 33 cities  throughout the United States.  TLSI's  consumer
direct  logistics  operation  is merely a single  product line within the larger
cash flow generating group of freight forwarding services.  Until June 30, 2003,
our consumer  direct  product line  operated  primarily  out of a single  office
within our office  network.  This  office was set up to  exclusively  handle the
consumer direct  logistics  product for a group of customers.  At the end of the
June 30, 2003 fiscal year, TLSI determined that the rates being charged were not
high enough for this office to turn a profit,  and it advised the customers that
the  rates for the  consumer  direct  services  will be  increased.  Some of the
customers  were not  receptive  to an increase so the office was closed down and
the balance of that office's  operations  were  transferred to another office in
the same city.  TLSI  continues to provide the consumer  direct  product to some
customers  formerly  serviced by the closed  office as well as to new  customers
through its other offices in the network.

The closing of the dedicated office was not the elimination of an operation, nor
was it the  discontinuance of the consumer direct services  product.  The action
was merely the closing of a single  office  which was  dedicated to the consumer
direct product.

* 500 Harborview Drive, Third Floor, Baltimore, Maryland 21230 * (770) 587-4185
                            * Fax (770) 587 - 9428 *

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                     [TARGET LOGISTICS, INC. LOGO]

Division of Corporation Finance
March 17, 2005
Page 2

COMMENT 2
---------
REPORT OF REGISTERED INDEPENDENT PUBLIC ACCOUNTING FIRM, PAGE F-1

Stonefied  Josephson,  Inc.  performed the audit for fiscal years ended June 30,
2002,  2003 and 2004.  The audit  report for fiscal year ended June 30, 2002 was
inadvertently  left out of their  audit  report for fiscal  year ending June 30,
2004.  However,  the audit report was included in the 10-K for June 30, 2003 and
2002.  Since the 2002 fiscal  year will not be included in our next 10-K,  we do
not  believe at this late date that an  amendment  would have any meaning to the
reader of the financials. Please advise whether the staff concurs.

COMMENT 3
---------
CONSOLIDATED STATEMENT OF OPERATIONS, PAGE F-3

A description of the SG&A expense line items are as follows:

         SG&A - Target subsidiary
         ------------------------
         Amounts shown include all SG&A incurred by TLSI EXCEPT for  commissions
         paid to TLSI's exclusive independent agents,  referred to as "exclusive
         forwarder commissions".

         SG&A - Target subsidiary (Exclusive forwarder commissions)
         ----------------------------------------------------------
         Amounts shown are the commissions paid to TLSI's exclusive independent
         agents.

Our exclusive  forwarder  commissions are similar to sales  commissions  paid to
TLSI's salaried sales employees;  accordingly,  the expense is included in SG&A.
Management  determined in 1999 to report  exclusive  forwarder  commissions as a
separate  line item  within  SG&A  since it is such a  significant  share of the
overall  SG&A  expense.  We do not believe  that any  additional  disclosure  is
required. Please advise whether the staff concurs.

COMMENT 4
---------
RECENT ACCOUNTING PRONOUNCEMENTS, PAGE F-10

We do not have an ownership in any variable interest entities.

* 500 Harborview Drive, Third Floor, Baltimore, Maryland 21230 * (770) 587-4185
                            * Fax (770) 587 - 9428 *

<PAGE>

                     [TARGET LOGISTICS, INC. LOGO]

Division of Corporation Finance
March 17, 2005
Page 3

COMMENT 5
---------
NOTE 7: DEBT, PAGE F-14

We will  include  the  amounts  outstanding  under the GMAC  credit  line in the
contractual  obligations and  commitments  table of MD&A (see page 12) in future
10-K filings. Please advise if the staff concurs.

COMMENT 6
---------
OTHER

We confirm that (i) the Company is responsible  for the adequacy and accuracy of
the  disclosure  in the  filings,  (ii) the SEC staff  comments  or  changes  to
disclosure in response to SEC staff comments in the filings  reviewed by the SEC
staff do not foreclose the Commission from taking any action with respect to the
filing,  and (iii) the Company may not assert SEC staff comments as a defense in
any  proceeding  initiated  by the  Commission  or any person  under the federal
securities laws of the United States.

Sincerely,

TARGET LOGISTICS, INC.

/s/ Philip J. Dubato
-----------------------
Philip J. Dubato
Chief Financial Officer

cc:  Mr. Stuart Hettleman
     Chief Executive Officer

* 500 Harborview Drive, Third Floor, Baltimore, Maryland 21230 * (770) 587-4185
                            * Fax (770) 587 - 9428 *
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