SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
                      DIVERSIFIED PRODUCT INSPECTIONS, INC.
                         1059 East Tri-County Boulevard
                         Oliver Springs, Tennessee 37830

                                                                   July 13, 2005

Mr. Jim B. Rosenberg Mail Stop 6010
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

      Re:   Diversified Product Inspections, Inc. (the "Company")
            Form 10-KSB for the year ended December 31, 2004
            File No. 000-25429

Dear Mr. Rosenberg:

      Reference  is made to  your  comment  letter,  dated  July 7,  2005 to the
Company  relating to the  above-captioned  filings (the "Comment  Letter").  Set
forth below are the Company's responses to the comments contained in the Comment
Letter.

      Prior to the conversion of the convertible  debt during 2004, we disclosed
in the notes to our financial statements in our 10-KSB filings for both the year
ended  December  31,  2002 and  December  31, 2003 that "the  debentures  may be
converted  at any time by the  Investor..."  and that "In the  event  all or any
portion of the  debentures  are  outstanding  at the end of three years from the
date of issuance,  the  debentures are subject to automatic  conversion...".  No
such disclosure was deemed necessary in the notes to our financial statements in
our December 31, 2004 10-KSB as the  debentures  had  previously  been converted
(and the conversion was disclosed).

      The comment regarding paragraph 19 of EITF 00-27, Application of Issue No.
98-5  to  Certain  Convertible  Instruments,  would  not  be  applicable  to our
convertible debt because it did not have a "stated  redemption date".  Paragraph
20 of EITF states that "For  convertible  instruments  that do not have a stated
redemption  date.......the  Task Force decided to retain the current guidance in
Issue 98-5". Per Case 5 of EITF 98-5, Accounting for Convertible Securities with
Beneficial Conversion Features or Contingently  Adjustable Conversion Ratios, if
"the security is immediately convertible,  the intrinsic value of the beneficial
conversion feature would be charged to interest expense at issuance". In regards
to our  convertible  debt,  the security  was  immediately  convertible  and the
intrinsic  value  of the  beneficial  conversion  feature  was thus  charged  to
interest  expense at issuance in 2002.  This was  disclosed  in the notes to our
financial  statements in our 10-KSB filings for both the year ended December 31,
2002  and  December  31,  2003  which  stated  "as a  result  of the  conversion
rate......which allow for the conversion at a price less than the stock price at
the date of  funding......the  Company recognized interest expense and increased
additional paid-in  capital.......at  the date of funding." Paragraph 21 of EITF
00-27 is not  applicable  to our  situation  as we had no  unamortized  discount
related to the beneficial conversion feature as EITF 98-5 required us to expense
the intrinsic value of the beneficial conversion feature at issuance in 2002.

<PAGE>

      In accordance with your request, we represent as follows:

(a) the Company understands that it is responsible for the adequacy and accuracy
of the disclosure in its filings;

(b) the Company  understands  that staff  comments or changes to  disclosure  in
response to staff  comments do not foreclose the SEC from taking any action with
respect to the filing; and

(c) the Company will not assert staff comments as a defense proceeding initiated
by the SEC or any other person under the federal  securities  laws of the United
States.

                                       Very truly yours,

                                       DIVERSIFIED PRODUCT INSPECTIONS, INC.

                                       By: /s/ John VanZyll
                                           -------------------------------------
                                           John VanZyll, President

</TEXT>
</DOCUMENT>