SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>v05462_corresp.txt
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                              ADZONE RESEARCH, INC.
                             4062 GRUMMAN BOULEVARD
                               CALVERTON, NY 11933

                                                                  August 9, 2004

Tracey Houser
Staff Accountnat
Division of Corporate Finance
Office of Small Business Operations
Securities and Exchange Commission
450 5th Street, N.W.- Mail Stop 4-6
Washington, D.C. 20549

            RE:      ADZONE RESEARCH, INC.
                     FORM 8-K ITEM 4 FILED AUGUST 4, 2004
                     FILE NO. 0-28717

Dear Ms. Houser:

      AdZone Research, Inc. (the "Company") a Delaware corporation, has today
filed a amendment to the above-referenced report. This letter responds to your
letter dated August 5, 2004 relating to comments of the staff of the Securities
and Exchange Commission in connection with the above-referenced submission.

      As requested, please note the following:

      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 no foreclose the
            Commission from taking 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 federal
            securities laws of the United States.

1.    PLEASE REVISE YOUR SECOND PARAGRAPH REGARDING THE AUDITOR REPORTS FOR THE
      TWO MOST RECENT YEARS, MARCH 31, 2004 AND MARCH 31, 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)(II) OF
      REGULATION S-B FOR GUIDANCE.

      As requested by the staff, we have revised the second paragraph of the
Form 8-K.

                               *******************

      We appreciate your timely consideration of these matters in your review of
the filing referenced above. If you or others have any questions or would like
additional information, please contact our consel, Darrin M. Ocasio at
212-930-9700.

                                               Very truly yours,

                                               Charles Cardona

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