SecProbe.io

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Mail Stop 0407

      							March 11, 2005

Mr. Philip M. Verges
Chief Executive Officer and Chief Financial Officer
NewMarket Technology Inc.
14860 Montfort Drive, Suite 210
Dalla, Texas 75254

RE:	NewMarket Technology, Inc.
	Form 8-K filed February 28, 2005
            File No. 0-27917

Dear Mr. Verges:

       We have the following comments with regard to the above
referenced filing.  We welcome any questions you may have about
our
comments.  Feel free to contact us at the telephone numbers listed
at
the end of this letter.

1. Please revise the Form to state whether the former accountant
resigned, declined to stand for re-election or was dismissed, and
the
specific date, as required by Item 304(a)(1)(i) of Regulation S-K.
It is not sufficient to state that the company "was notified that
Durland & Company, CPAs, PA would not be able to act as the
Company`s
independent auditors," as that wording is unclear to a reader.

2. In addition, please revise to comply with Item 304(a)(1)(ii) of
Regulation S-K which requires a statement whether the accountant`s
report on the financial statements for either of the past two
years
contained an adverse opinion or a disclaimer of opinion or was
qualified or modified as to uncertainty, audit scope or accounting
principles; and a description of the nature of each such adverse
opinion, disclaimer of opinion, modification or qualification.
This
would include disclosure of uncertainty regarding the ability to
continue as a going concern in the accountant`s report.

3. Finally, in the third paragraph of Item 4.01(a) you state
"during
the Registrant`s two most recent fiscal years and during any
subsequent interim period prior to the resign as the Company`s
independent auditors."  Please clarify this sentence by the
stating
the date of resignation.

 	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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 comments on your filing.

	Please provide the supplemental information requested above
within 10 business days from the date of this letter.  The
supplemental information should be filed as correspondence on
EDGAR.
The amendment requested in the first comment above should be filed
as
promptly as possible and should be reviewed by the former
accountants.  The letter required by Exhibit 16 should cover the
revised disclosures.  Any questions regarding the above should be
directed to me at (202) 824-5288, or in my absence, to Robert
Benton
at (202) 942-1811.

							Sincerely,

							Inessa Berenbaum
						            Staff Accountant

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Mr. Philip Verges
NewMarket Technology Inc.
March 11, 2005
Page 2

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

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