SecProbe.io

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      February 8, 2005

Mail Stop 04-09

Mr. Timothy Shannon
Chief Executive Officer
Dale Jarrett Racing Adventure, Inc.
3604 Denver Drive
Denver, CO 28037

Re:	Dale Jarrett Racing Adventure, Inc.
	Form 10-K for the year ended June 30, 2004
	File No. 000-27251

Dear Mr. Shannon:

We have reviewed your filing and have the following comments.  We
have limited our review to `Cost of Sales` and `Stock Issued in
Exchange for Services` and will make no further review of your
documents.  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.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

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 any other aspect of
our
review.  Feel free to call us at the telephone numbers listed at
the
end of this letter.

Comments

Item 6. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations, page 9
1. We note that the Company includes depreciation on its vehicles
within general and administrative expenses.  Please explain how
the
Company determined that depreciation on its racing vehicles and
shop
and track equipment should be included within general and
administrative versus cost of sales.  Also, supplementally explain
and in future filings revise to disclose in a footnote the type of
expenses included in cost of sales.

Note 4. Stockholders` Deficit, page 31
2. We note that the Company issued shares of its common stock to
vendors for services provided.  Supplementally provide a breakdown
of
such issuances for the last two fiscal years that includes the
number
of shares issued, the fair value assigned to such shares and the
date
used to value the issuances.  Please explain how the Company
considered EITF 96-18 in determining the measurement date in
determining fair value.

As appropriate, please respond to these comments within 10
business
days.  Please file your cover letter on EDGAR.

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

* 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.

You may contact Kelly McCusker, Staff Accountant, at (202) 824-
5453
or myself at (202) 942-2814 if you have questions regarding
comments
on the financial statements and related matters.

						Sincerely,

Kathleen Collins
Accounting Branch Chief

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Dale Jarrett Racing Adventure
February 8, 2005

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