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CORRESP
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      Univec Correspondence

    UNIVEC

    4810
      Seton Drive

    Baltimore,
      MD 21215

    Telephone:
      (410) 347-9959

    Fax:
      (410) 347-1542

    November
      18, 2005

    Securities
      and Exchange Commission

    Washington,
      D.C. 20549

        Re:
      Univec,
      Inc. (Registrant)

      File No. 000-22413

    Gentlemen,

    This
      letter is in response to the Securities and Exchange Commission (SEC) comment
      letter to the above referenced Registrant dated September 29, 2005. This letter
      addressed the Registrant’s Form 10-KSB for the Year Ended December 31, 2004 and
      the Forms 10-QSB for the Quarters Ended March 31, 2005 and June 30, 2005,
      respectively.

    SEC
      comment number:

            1)

              Liquidity
                and Capital Resources, Page 11 -

              “Viable
      Plan” to generate positive cash: The
      Form
      10-KSB states that the Registrant’s management
      is currently seeking additional investment
      capital to support its entrance intoc new
      business ventures and provide the capital needed
      to operate. Further, in Part I, Item 1 the Registrant
      states that during late 2004 the company
      was established as a distributor of specialty
      and highly regulated pharmaceutical products.
      The company intends to expand the product
      line to take further advantage of its group purchasing
      and closed systems purchasing. Additionally,
      In 2004 the Company applied for and received
      a Provisional Patent from the U.S. Patent and
      Trademark Office on September 21, 2004, the Patent #60/611,670 and Foreign
      Filing License Granted October 15, 2004, code US60/611,6700 .… In brief
      description, a medical device with a sliding sheath to protect caregivers in
      the
      dental and cosmetic markets.

                These
      significant new
      products are anticipated to provide the company with revenue sources and gross
      profits which will adequately support its continued operations. Because of
      their
      prior discussion in the Description of the Business segment of the Form 10-KSB,
      management considers any suggested revisions to Note 3 to the financial
      statements to be repetitious in these circumstances.

        -1-

            2)

              Significant
                Estimates, Page 12

    In
      response to comment # 2 regarding significant estimates, we intend to amend
      our
      Significant Estimates segment of the Managements Discussion and Analysis section
      of the year-ended December 31, 2004 Form 10-KSB.

    In
      conformity with interpretive MD&A guidance provided in Release 33-8350, we
      intend to provide a discussion of significant estimates and assumptions involved
      in the Company’s application of GAAP.

    The
      Company’s amendment to this section will specifically expand the discussion of
      the 2004 conclusion to write-off the entire $1,774,119 balance of impaired
      goodwill. Further, the Company will discuss its method of determining the
      adequacy of its reserve for losses on litigation. Finally, the amendment will
      discuss the methods used in valuing equity securities which were issued in
      payment of various corporate obligations.

            3)

              Controls
                and Procedures, Page 13 -

    In
      SEC
      Release 33-8350 interpretive MD&A guidance is presented for reporting the
      Registrant’s annual conclusions regarding management’s evaluation of controls
      and procedures. In accordance with such guidance:

    (a)
      Item
      8A of Form 10-KSB for the year ended December 31, 2004 incorrectly states that
      the “Evaluation Date” for the Registrant’s assessment of the Company’s
      disclosure controls and procedures (as defined in Exchange Act Rules
13a-14(c)
      and 15-d-14(c) was concluded within 90 days of the filing date of the quarterly
      report.

                The
      Registrant agrees
      that this definition of the  “Evaluation
      Date”, as stated in the Form 10-KSB is incorrect.
      Therefore, a Form 10-KSB amendment will
      be
      filed to properly state that the “Evaluation Date”
was
      concluded within 90 days of the filing date
      of
      the Form 10-KSB annual report. The amendment
      will state that the evaluation concluded
      that as of the Evaluation Date, the Company's
      disclosure controls and procedures were
      adequate and effective to ensure that
      material information relating to the Company and
      its
      solidated subsidiaries would be made known
      to
      them by others within those entities, particularly
      during the period in which this annual report
      was being prepared.

                (b)
      Changes in
      internal controls. There were no significant
      changes in the Company's internal controls
      or in other factors that could significantly affect
      the Company's disclosure controls and procedures
      subsequent to the Evaluation Date, nor any
      significant deficiencies or material  weaknesses
      in such disclosure controls and procedures
      requiring corrective actions. As a result,
      no corrective actions were taken.

            4)

              Controls
                and Procedures - “Effective”, Page 13
                -

    As
      noted
      in your September 29, 2005 comment letter, the language which appears in Item
      8A
      after the word effective does not fully comply with the definition of disclosure
      of disclosure controls and procedures as contained bin Rule 13a-15(e) of the
      Exchange Act. Therefore, we will amend the filing so that Item 8A will end
      with
      the word “effective”.

            5)

              In
                view of the restatement of the 2003 financial statements, as reported
                in
                the year-ended December 31, 2004, our certifying officers have concluded
                that all disclosure controls and procedures at the end of the period
                covered by the December 31, 2004, as well as the quarters ended March
                31,
                2005 and June 30, 2005, respectively, have effectively resulted in
                accurate and timely reporting of the Registrant’s financial results of
                operations. This enhancement has resulted from a detailed examination
                and
                assessment of the Company’s financial transactions as well as from
                extensive discussions conducted with the Registrant’s independent
                Certified Public Accountants.

            6)

              The
                Registrant’s auditor acknowledges that they will amend their opinion of
                the 2003 financial statements as being “restated”. Further, they will
                specifically amend the Form 10-KSB to refer to the footnote which
                describes the restatement.

            7)

              The
                Company will label the appropriate 2003 financial statements as being
                “restated”. Also, the Company will refer to the footnote which describes
                the restatement when it amends the December 31, 2004 Form
                10-KSB.

            8)

              The
                inventory write-downs for 2004 of $75,000 and 2003 of
                $50,000, respectively will be revised to report them as components
                of cost
                of sales when the amended December 31, 2004 Form 10-KSB is
                submitted.

        -2-

            9)

              During
                2004 a $144,819 gain on the extinguishment of debt was recognized.
                This
                gain was realized from corporate contractual arrangements which were
                revised during 2004 to repay vendors in amounts less than was previously
                determined in accordance with the original agreements. Such gains
                were
                computed by the measurement of the original balance due versus the
                revised
                settlement balance due to the vendors, which was accepted as
                settlement-in-full for the
                obligations.

            10)

              The
                comparative 2004 and 2003 Consolidated Statement of
                Operations recognized a loss from discontinued operations of $8,320
                and
                $93,502, respectively. These amounts represent the net 2004 (current
                period) and 2003 (prior period) comparative operating losses from a
                subsidiary, which was completely disposed of during August 2004 (SFAS
                144
                paragraph 43).

    The
      Registrant’s Note 18 to the Form 10-KSB for the fiscal year-ended December 31,
      2004 describes the terms of the settlement in detail. The actual 2004 $597,055
      loss on sale of the subsidiary was reported as a separate line item on the
      year-ended December 31, 2004 Statement of Operations (SFAS 144 paragraph
      43).

    SFAS
      144
      paragraph 41 states that “a component (including a subsidiary) of an entity
      comprises operations and cash flows that can be clearly distinguished,
      operationally and for financial reporting purposes, from the rest of the
      entity.” SFAS 144 paragraph 42 requires that “the results of operations of a
      component of an entity that either has been disposed of or is classified as
      held
      for sale shall be reported in discontinued operations in accordance with
      paragraph 43 if both of the following conditions are met: (a) the operations
      and
      cash flows of the component have been (or will be) eliminated from the ongoing
      operations of the entity as a result of the disposal transaction and (b) the
      entity will not have any significant continuing involvement in the operations
      of
      the component after the disposal transaction. Finally, SFAS 144 paragraph 44
      states that “adjustments to amounts previously reported in discontinued
      operations that are directly related to the disposal of a component of an entry
      in a prior period that are directly related to the disposal of a component
      of an
      entity in a prior period shall be shall be classified separately in the current
      period in discontinued operations.” The Registrant had no such prior period
      adjustments during 2004 or 2003.

    Due
      to
      the Registrant’s adherence to the provisions of SFAS 144, as previously
      specified, the Company believes that no revisions are required to be made to
      Note 18 of the Form 10-KSB for the fiscal year-ended December 31, 2004.

            11)

              During
                2004 the Company acquired $397,068 of equipment
                as cash uses reported in the Cash Flows from Financing in the Consolidated
                Statement of Cash Flows. The source of such cash is reported in the
                cash
                flows from Financing Activities as reported in the Cash Flows from
                Investing Activities in the Consolidated Statement of Cash Flows.
                The
                financial elements of these activities have been reported Note 8
                of the
                Consolidated Financial Statements. However, in accordance with paragraph
                95 of SFAS 95, the proceeds of the 2003 net capitalized lease obligation
                of $250,000 has been reported as a 2003 cash transaction in Note
                2 -
                Restatement footnote to the Consolidated Financial Statements.

            12)

              Note
                2 - Restatement of the 2003 financial statements occurred as a result
                of a
                prior year  transaction,
                which
                resulted from an affiliated company’s
                equipment capital lease refinancing of certain
                Company equipment. The original 2003 financial
                statements inaccurately reported this transaction.
                When the oversight was discovered during
                the 2004 examination of the financial statements,
                it was reported in Note 2 as being a  restatement
                of the
                prior year financial
                statements.

            13)

              APB
                26 and paragraph 26 of APB 9 require the responsible party to quantify
                the
                restatement of the prior erroneous financial statements. The responsible
                party is also required to provide detail components of the prior
                statements. The Company will issue such required components in an
                amendment to the year-ended December 31, 2004 Form 10-KSB.

        -3-

            14)

              Note
                17 - Concentrations

    Your
      comment letter asked us to revise this note and to describe the nature and
      terms
      of our corporate group purchasing sales arrangements with our affiliate,
      Pharmacy Services, Inc. (PSI).

    These
      details will be provided in an amendment to the year-ended December 31, 2004
      Form 10-KSB.

            15)

              Revenue
                Recognition

    Your
      comment letter asked us to provide a relevant analysis of the Company’s Gross
      vs. Net method of revenue reporting as stipulated by the provisions of EITF
      99-19.

    EITF
      99-19 registers several factors which indicate that Gross reporting of sales
      revenue is preferential. These factors, together with the Company’s relevant
      circumstances include:

            ·

              The
                Company (not the supplier) is the primary obligor in the arrangement.
                In
                this matter, the Company renders all
                pertinent payments on a monthly basis.

            ·

              The
                Company (not the supplier) maintains general inventory risk. The
                Company
                is primarily responsible for maintenance of the
                goods.

            ·

              Latitude
                in establishing the price of goods rests with the Company. In this
                case,
                the Company is responsible for paying the supplier the specified
                prices.
                However, the Company retains flexibility in determining which supplier
                will provide the product.

            ·

              The
                Company changes the product or performs part of the service. In this
                case,
                the Company retains absolute control over which product is provided
                to the
                user.

            ·

              The
                Company has discretion in supplier selection. In this case, the Company
                retains absolute control in selection of the
                supplier.

            ·

              Product
                or service specifications are determined in part by the Company.
                In this
                case, the Company defines all product
                specifications.

            ·

              Physical
                loss inventory risk exists for the Company. As previously stated,
                the
                Company has (not the supplier) maintains general inventory risk.
                The
                Company is primarily responsible for maintenance of the
                goods.

            ·

              The
                Company has credit risk. In this ar