SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>projectletter.txt
<DESCRIPTION>FORM 8-K ITEM 4 DTD 10/22/04 MEW
<TEXT>

					October 22, 2004

Mail Stop 0409

VIA U.S. MAIL

Mr. Craig Crawford
President
The Project Group, Inc.
333 North Sam Houston Parkway East
Suite 275
Houston, TX  77060

Re:	The Project Group, Inc., Form 8-K filed October 22, 2004

Dear Mr. Crawford:

We have reviewed your filing and have the following comment.  Where
indicated, we think you should revise your document in response to
this comment.  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 on any other aspect of
our review.  Feel free to call me at the telephone number listed at
the end of this letter.

1. We note from your former accountant`s (Thomas Leger & Co., LLP)
SECPS letter dated October 13, 2004, that your relationship with them
has ceased due to Section 206 of Sarbanes-Oxley Act of 2002.  Note
that Section 206 refers to the conflicts of interest matter related
to your accountants. In that regard, tell us as to the nature of
these conflicts and why the former accountants can no longer be
engaged as your auditor. Also, provide us with information describing
the periods these conflicts occurred and how the conflicts impact
previously issued financial statements.
2. Also, please look at Item 4.02 of Form 8-K.  You may be required
to file an Item 4.02 Form 8-K if previously issued financial
statements can no longer be relied upon.  Please advise.

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 comment, 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 above should be filed as promptly as possible and
should be reviewed by the newly engaged accountants before filing
with the Commission.

You may reach me at (202) 942-2913 with any questions.

						Sincerely,

						Andrew Mew
						Staff Accountant

Project Group, Inc.
October 22, 2004

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