SecProbe.io

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<TYPE>LETTER
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<FILENAME>filename1.txt
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Mail Stop 3561

							October 19, 2005

Bernard L. Brodkorb
President
ISA International, Inc.
2560 Rice Street
St. Paul, MN  55113

RE:	ISA International, Inc.
	Item 4.01 Form 8-K filed October 19, 2005
            File No. 1-16423

Dear Mr. Brodkorb:

          We have reviewed your filing and have the following
comments.  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.

          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 contact us at the telephone numbers
listed
at the end of this letter.
1. Please revise to state if there were any disagreements with the
former accountants for either of the two most recent fiscal years
or
the subsequent interim period through the date of resignation.  It
is
suggested you use the date of resignation or state the actual date
of
October 13, 2005.  In this regard it is noted that if you use
terminology such as "through the date of this report," that it may
not be accurate since you have dated your report October 19, 2005
rather than October 13, 2005.  Please revise.
2. You state near the end of your disclosure that you are
including a
letter from Stonefield Josephson confirming their resignation.
Please note that the letter was not filed as an exhibit and that
it
is not the proper letter.  You are required to include a letter
stating whether or not your former accountants agree with the
disclosures in the filing.  Please revise to file the letter
required
by Item 304(a)(3) of Regulation S-B.

Bernard L. Brodkorb
ISA International, Inc.
October 19, 2005
Page 2

3. In a letter dated August 26, 2005 we cited certain comments
related to your prior Item 4 Form 8-K filed August 5, 2004.  You
may
want to respond to the comments relating to the change in
accountants
and file the Form 8-K/A we requested separately from responding to
the Form 10-KSB comments.  Please tell us the status of responding
to
the change in accountants comments in our August 26, 2005 comment
letter to you.

      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
disclosures 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 this action 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 connection with our review of
your
filing or in response to our comments on your filing.

	As appropriate, please amend your filing and respond to these
comments within five business days or tell us when you will
respond.
Please furnish a cover letter with your amendment that keys your
responses to our comments and provides the representations
requested
above.  Please file the cover letter as correspondence on our
EDGAR
system.   Any questions regarding the above should be directed to
Robert Burnett, Staff Accountant, at (202) 551-3330, or in his
absence, to me at (202) 551-3841.

							Sincerely,

							Michael Moran
						            Branch Chief

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