SecProbe.io

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							May 3, 2005

Mail Stop 0305

 BY U.S. Mail and Facsimile [ (973) 233 - 1299 ]

 Mr. Eduardo Rodriguez
  Chief Executive Officer
GLOBAL CONCEPTS, LTD.
14 Garrison Inn Lane
Garrison, New York  10524

 	Re:	Global Concepts, Ltd.
 		Item 4.01 Form 8-K, filed March 9, 2005 and
 		Item 4.01 Form 8-K, filed April 21, 2005
 		File No. 0-25319

Dear Mr. Rodriguez:

	We have reviewed the above referenced filings for compliance
with the requirements with respect to the Item 4.01 disclosures of
the Form 8-K.  Where indicated, we think you should revise your
document in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.

	Pursuant to Rule 101(a)(3) of Regulation S-T, your response
should be submitted via EDGAR, under the label "corresp," within 5
business days of the date of this letter.  Please note that if you
require longer than 5 business days to respond, you should contact
the staff immediately to request additional time.  An amendment to
each of the Item 4.01 Forms 8-K should be filed immediately.

	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.

May 3, 2005

Mr. Eduardo Rodriguez
Global Concepts, Ltd.
Page 2

ITEM 4.01 FORM 8-K
(Filed March 9, 2005)

1. With respect to the Item 4.01 Form 8-K filed on March 9, 2005,
we
note that the Exhibit 16.1 letter from Bagell, Josephs & Company,
LLC, your previously former auditors, was to be filed by
amendment.
Please amend the March 9, 2005 Form 8-K filing immediately to
include
the Exhibit 16.1 letter from the former auditors, Bagell, Josephs
&
Company, LLC.  Please note the Exhibit 16.1 letter was required to
be
filed no later than 10 business days after the initial filing of
the
Item 4.01 Form 8-K.  See Item 304(a)(3) of Regulation S-B.

ITEM 4.01 FORM 8-K
(Filed April 21, 2005)

2. In addition, with respect to the Item 4.01 Form 8-K filed on
April
21, 2005, please amend this filing to include, as Exhibit 16.1, a
letter from Joseph Troche, CPA, your former principal independent
accountant, indicating whether or not they agree with your
disclosures in the amended Item 4.01 Form 8-K.  Reference is made
to
Item 304(a)(3) of Regulation S-B.

Other

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

May 3, 2005

Mr. Eduardo Rodriguez
Global Concepts, Ltd.
Page 3

* 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 comments on your filing.

Closing Comments

	Any questions concerning the above comments may be directed
to
the undersigned at (202) 551-3328.

							Sincerely,

							Beverly A. Singleton
							Staff Accountant

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