SecProbe.io

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                                 [LOGO OF a21]

November 3, 2005

Mr. Robert Telewicz
Staff Accountant
Division of Corporation Finance
United States Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549

Re:  a21, Inc. (the "Company")
     Item 4.02 Form 8-K
     File no. 000-51285

Dear Mr. Telewicz:

We respectfully respond to your captioned letter as follows:

On September 20, 2005, the Company filed an amendment to its Form 10-KSB for the
year ended December 31, 2004, an amendment to its Form 10-QSB for the three
months ended March 31, 2005, and a Form 8-K/A to disclose, among other things,
revisions to its financial statements resulting from additional debt discount
and additional paid-in capital that were required to be reflected due to the
existence of a beneficial conversion feature in its then outstanding convertible
subordinated notes. In addition, the Company determined that it had not properly
reflected the allocation of goodwill and a deferred tax liability in conjunction
with the SuperStock acquisition in February 2004.

In light of these revisions, the Company's certifying officers reconsidered the
effect of the adequacy of the Company's disclosure controls and procedures for
each of its quarterly reports filed in 2004, its annual report for the year
ended December 31, 2004 and its quarterly report for the first quarter of 2005.
The Company believes that through detailed discussion of these matters in the
Controls and Procedures section of its Form 10-QSB for the quarter ended June
30, 2005 (the "2Q Form 10-QSB") and Form 8-K/A it has adequately disclosed the
matter especially in light of the fact that the convertible subordinated notes
(to which the beneficial conversion feature relates, and which accounts for the
largest portion of the adjustments - all of which were noncash items) were
repaid in the first quarter of 2005. Management believes that the inclusion of
identical disclosure of these matters in filings for earlier periods will not
further advance the interests of the Company's stockholders or enhance the
credibility of the Company's financial reporting.

The Company disclosed in the 2Q Form 10-QSB a material weakness in the design or
operation of internal controls that could adversely affect its ability to
record, process, summarize and report interim financial data. The material
weakness identified pertained specifically to the recording of convertible debt
instruments (which the Company has since repaid) and deferred tax assets.

                 7660 Centurion Parkway, Jacksonville, FL 32256
               904.565.0066 | info@a21group.com | www.a21group.com
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Upon determining that there were material weaknesses in its disclosure controls
and procedures (specifically, its internal controls over financial reporting),
the Company's management, with the oversight of its Audit Committee, promptly
commenced an assessment of the factors that contributed to such weaknesses and
the steps that needed to be taken to remediate the Company's disclosure controls
and procedures. The Company's management, with the oversight of its Audit
Committee, has taken steps to remediate the material weaknesses identified in
its 2Q Form 10-QSB, which include:

o     Improving the Company's internal financial reporting team. The Company is
searching for a new chief financial officer with the requisite experience in
accounting and public company reporting as well as the ability to lead the
financial reporting team and work closely with senior management. The Company is
also searching for additional financial reporting staff to supplement its
existing financial reporting team's public company reporting capabilities.
Additionally, the Company is planning on increasing the training in financial
and public company reporting that it provides to its personnel.

o     Retaining an outside professional resource firm. The Company has retained
an independent professional resource firm (i.e., in addition to its independent
accountants) to assist it in various financial reporting functions, including
complying with SEC reporting requirements and assessing the adequacy of
disclosure controls and procedures.

The Company believes that these actions will address the material weaknesses
that affected its disclosure controls and procedures, and specifically its
internal controls over financial reporting, as of its December 31, 2005 fiscal
year end. The Company also believes that these material weaknesses have been
adequately disclosed in its previous public filings.

Additional Statements:

a21, Inc. acknowledges that it is responsible for the adequacy and accuracy of
the disclosures in the filings.

a21, Inc. acknowledges that SEC staff comments or changes to disclosure in
response to staff comments in its filings reviewed by the SEC staff do not
foreclose the SEC from taking any action with respect to the filings.

a21, Inc. acknowledges that it may not assert staff comments as a defense in any
proceeding initiated by the SEC or any person under the federal securities laws
of the United States.

                                           Very truly yours,
                                           /s/ Thomas V. Butta
                                           -------------------------------------
                                           Thomas V. Butta
                                           President and Chief Financial Officer

                 7660 Centurion Parkway, Jacksonville, FL 32256
               904.565.0066 | info@a21group.com | www.a21group.com
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