SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>adzone8kswhltr852004.txt
<DESCRIPTION>8/5/2004 COMMENT LETTER ON ITEM 4, 8-K; HOUSER
<TEXT>

August 5, 2004

Charles Cardona
CEO
Adzone Research, Inc.
4062 Grumman Boulevard
Calverton, New York  11933

RE:  	Form 8-K Item 4 filed August 4, 2004
	File # 0-28717

Dear Mr. Cardona:

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.  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 comment or on any other aspect of our
review.  Feel free to call us at the telephone number listed at the
end of this letter.

	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.

1. Please revise your second paragraph regarding the auditor reports
for the two most recent years, March 31, 2004 and 2003, to make it
clear that the accountant`s report did not contained an adverse
opinion or a disclaimer of opinion or was qualified or modified as to
uncertainty, audit scope or accounting principles, except that SWH
expressed substantial doubt with respect to the Company`s ability to
continue as a going concern for both fiscal years.  Refer to Item
304(a)(1)(ii) of Regulation S-B for guidance.

*****

Please file your supplemental response and amendment via EDGAR in
response to these comments within 5 business days of the date of this
letter.  Please note that if you require longer than 5 business days
to respond, you should contact the staff immediately to request
additional time.  Direct any questions regarding the above to the
undersigned at (202) 942-1989.

Sincerely,

Tracey Houser
Staff Accountant
Mr. Cardona
Adzone Research, Inc.
August 5, 2004
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

       DIVISION OF
CORPORATION FINANCE

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