SecProbe.io

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<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>v07911_corresp.txt
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                                          October 28, 2004

U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

Attention: Andrew Mew

      Re:   The Project Group,  Inc. (the  "Company")
            Form 8-K filed October 22, 2004
            Letter Dated October 22, 2004

Dear Mr. Mew:

      In response to your letter, referenced above, relating to the referenced
Form 8-K filing reporting the termination of the Company's prior audit firm,
please find the following responses:

      1.    The background of the termination of the Company's relationship with
its former accountants, Thomas Leger & Co., L.L.P. ("TL&C"), is as follows: Ms.
Charlsie Idol, a staff member of TL&C and a member of the engagement team for
the Company resigned from TL&C on September 30, 2004. On October 13, 2004,
management of the Company discussed with TL&C its intent to hire Ms. Idol as
Controller and its corresponding determination to terminate its relationship
with TL&C. On that date, TL&C prepared a letter to the Company indicating that
the client-auditor relationship had ceased due to "Section 206 of Sarbanes-Oxley
Act of 2002". On October 15, 2004, Ms. Idol was hired as the Controller of the
Company. On October 18, 2004, the Company received the letter of October 13
advising that the client-auditor relationship had terminated.

      Management's decision to hire Ms. Idol, a former member of the audit
engagement team, was the specific event that gave rise to the Section 206
conflict and the termination of the client-auditor relationship.

      The conflict in question arose upon the hiring of Ms. Idol and does not
impact any previously issued financial statements.

      2.    Because the conflict in question does not impact any previously
issued financial statements, no disclosure is required under Item 4.02 of Form
8-K regarding non-reliance on previously issued financial statements.

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      Based on the foregoing facts, the Company believes that the disclosure in
the referenced Form 8-K is in accordance with the requirements of Items 4.01 and
4.02 of Form 8-K and Item 304 of Regulation S-K. Accordingly, the Company does
not believe that an amendment to the referenced Form 8-K is necessary.

      In responding to the SEC staff's comments regarding the referenced
filings, the Company hereby acknowledges that:

      o     the Company is responsible for the adequacy and accuracy of the
            disclosure in the filings;

      o     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

      o     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.

      Should you have any questions regarding the foregoing responses, please
feel free to contact the undersigned, or Ms. Idol, at (713) 622-1100 or the
Company's counsel, Michael Sanders, at (832) 446-2599.

                                               Sincerely,

                                               THE PROJECT GROUP, INC.

                                               /s/ Craig Crawford

                                               Craig Crawford
                                               President

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