SecProbe.io

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Mail Stop 4561

      September 22, 2005

Michael Siu
Chief Financial Officer
Tramford International Limited
Room 2413-18, Shui On Centre
8 Harbour Road
Wanchai, Hong Kong
+852 3112 8461

	Re:	Tramford International Limited
		Form 20-F: For the Fiscal Year Ended December 31, 2004
		Filed June 30, 2005
      File No. 000-29008

Dear Mr. Siu,

      We have reviewed the above referenced filing and have the
following comments.  Please note that we have limited our review
to
only your financial statements and related disclosures and do not
intend to expand our review to other portions of your document.
We
may ask you to provide us with supplemental information so we may
better understand your disclosure.  Please be as detailed as
necessary in your explanation.  After reviewing this information,
we
may 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 comment 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 20-F for the fiscal year ended December 31, 2004

Controls and Procedures, page 55

1. We note that your Chief Executive Officer and Chief Financial
Officer completed the evaluation of your disclosure controls and
procedures within the 90-day period prior to the filing date of
the
Form 20-F for the year ended December 31, 2004.  Your evaluation
should be as of the end of the period covered by the report
pursuant
to Item 15(a) of Form 20-F.  Please confirm whether your
disclosure
controls and procedures, as defined by Rule 13a-15(e) of the
Exchange
Act, were effective as of December 31, 2004.

2. We note your disclosure that no significant changes were made
to
your internal controls or other factors that could significantly
affect these controls subsequent to the date of their evaluation.
Consistent with the disclosure required by Item 15(d) of Form 20-
F,
please confirm to us definitively whether there was any change in
your internal control over financial reporting identified in
connection with your evaluation that occurred during the period
covered by the annual report that has materially affected or is
reasonably likely to materially affect your internal control over
financial reporting.  Please see Rule 13a-15(d) of the Exchange
Act
and Section II.F.4 of Release No. 33-8238 for additional guidance.

Financial Statements

Notes to the Consolidated Financial Statements

Note 2. Summary of significant accounting policies

(f) Intangible assets, page F-9

3. We note that the intangible asset represents the technology
platform for development of the server switch and network security
device.  Tell us whether the acquired software is within the scope
of
SFAS 86.  If so, tell us how you considered the guidance in
question
17 of the FASB Staff Implementation Guide to SFAS 86 which
indicates
that you should report amortization of these types of costs as a
component of cost of sales.

Note 18. Subsequent events, page F-18

4. We note that, in February 2004, you decided to dispose of the
information technology consultancy reporting unit and, in March
2005,
the operating unit was sold.  Tell us how you considered
paragraphs
30, 42 and 43 of SFAS 144 in your presentation of the results of
the
information technology consultancy reporting unit in your
consolidated financial statements.  In this regard, explain what
consideration you gave to presenting the results of operations of
your information technology consultancy reporting unit as
discontinued operations and the related assets and liabilities as
held for sale as of December 31, 2004.

*	*	*	*	*

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing any amendment and your responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; 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 filing or in
response to our comment on your filing.

      You may contact Steve Williams at (202) 551-3478 or Melissa
Walsh at (202) 551-3224 if you have any questions regarding our
comments on the financial statements and related matters.  Please
contact me at (202) 551-3730 with any other questions.

							Sincerely,

							Stephen Krikorian
      						Accounting Branch Chief

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Michael Siu
Tramford International Limited
September 22, 2005
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