SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 03-08

								March 22, 2005

By Facsimile and U.S. Mail

Mr. James N. Jannello
Chief Executive Officer
Janel World Trade, LTD.
150-14 132nd Avenue
Jamaica, NY 11434

	RE:	Form 10-K for the fiscal year ended September 30, 2004
		File Date: December 28, 2004
		File No. 333-60608

		Form 10-Q for the quarterly period ended December 31,
2004

Dear Mr. Jannello:

	We have reviewed your responses contained in the letter dated
March 15, 2005 and upon reviewing those responses issue the
following
comments.

	We welcome any questions you may have about our comments or
on
any other aspect of our review.  Feel free to call us at the
telephone numbers listed at the end of this letter.

General
1. As previously requested in our letter dated February 15, 2005,
please provide in writing a statement from the company
acknowledging
that:
a. The company is responsible for the adequacy and accuracy of the
disclosure in the filing;

b. 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
c. 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.

Form 10-K for Fiscal Year Ended September 30, 2004

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

Results of Operations - Fiscal Year Ended September 30, 2004
Compared
to Fiscal Year Ended September 30, 2003, page 15
2. We read your response to prior comment number 1 and do not
believe
you have adequately addressed our comment.  In particular, your
explanation of the decrease in revenues in the three months ended
December 31, 2004 as compared to the three months ended December
31,
2003 still does not allow the reader to understand the degree to
which each of the factors you identify contributed to the overall
decrease in revenues.  To the extent you can provide additional
value
to the reader by quantifying the factors that contributed to the
change in your revenues please do so in future filings.  For
further
guidance we again refer you to Item 303(a)(3) of Regulation S-K
and
the Commission`s Interpretative Release on MD&A, Release 33-8350,
which is available on the SEC`s website at www.sec.gov.

Item 8.  Financial Statements and Supplementary Data

Consolidated Financial Statements

Independent Auditors` Report
3. We note your response to prior comment number 8.  Please ensure
the amended filing addresses our prior comments 18 through 20
regarding your Section 302 Certifications and your Item 9A
disclosures.  The entire Form 10-K should be included in the
amended
filing.

Consolidated Statements of Operations
4. We read your response to prior comment number 10 and are
unclear
as to why you would include interest income and interest expense
within income from operations, as these appear to be non-operating
items.  Please advise.  Refer to Rules 5-03.7 and 5-03.8 of
Regulation S-X.

Consolidated Statements of Changes in Stockholders` Equity
5. We read your response to prior comment number 11.  Please
confirm
that you will reflect this reclassification on a retroactive basis
in
your next filing on Form 10-Q and that you will disclose the
nature
of the reclassification in the notes to the financial statements.
Also show us supplementally how the explanatory note will read.

Note 1 - Summary of Significant Accounting Policies

Revenue Recognition
6. We read your response to prior comment number 15, along with
your
proposed revision to your revenue recognition policy.  We still
find
your revenue recognition policy somewhat unclear.  As previously
requested, please revise your revenue recognition policy to
clearly
describe each of your revenue generating activities and to
separately
explain your revenue recognition policy for each material source
of
revenues.  The disclosure should indicate whether you record
revenues
in each case on a gross or a net basis, and why.  In this regard,
we
find your proposed disclosure confusing in that you state
"[r]evenues
recognized in other capacities include only the commissions and
fees
earned. . .," and yet you also state that "[r]evenues from all
categories are recorded on a gross basis. . ."  The first
statement
seems to imply that you record revenues on a net basis in certain
cases, which is inconsistent with the second statement.  Moreover,
it
is not sufficient to say that you record revenues on a gross basis
because it is standard industry practice; rather, you should
disclose
the basis in GAAP for your accounting.  Finally, with respect to
the
timing of revenue recognition, please ensure your disclosure is
clear
in terms of the timing of revenue recognition for each source of
revenues and also in terms of the basis in GAAP for recording
revenues at this time.  Again, show us supplementally what the
revised disclosures will look like in future filings.

Note 8 - Stockholders` Equity
7. We read your response to our prior comment number 17 and
understand that you determined the fair value of the restricted
stock
based on the price quotations on the OTC Bulletin Board for your
common stock on the issuance date (at $.01/share).  However, we
note
that there was no trading at this price on the issuance date, nor,
as
you point out, was there any trading in the stock for a
considerable
period of time prior to the issuance date.  Moreover, we note that
three days after the restricted stock issuance, on July 25, 2002,
there was actual trading volume for your stock at $3.75 per share.
Then starting on August 14, 2002, less than one month after the
restricted stock issuance, active trading of your stock on a daily
basis began.  Between August 14, 2002 and August 30, 2002, your
stock
traded at prices ranging from $1.08 per share to $2.10 per share.
Thus, it does not appear that the price quotation you used to
measure
the fair value of the restricted stock issuance on July 22, 2002
necessarily represents the fair value of the issuance.  While we
agree that quoted market prices in active markets are the best
evidence of fair value, in the absence of quoted market prices in
active markets, the estimate of fair value must be based on the
best
information available in the circumstances.  We also believe that
your disclosure in footnote 8 that these shares of restricted
common
stock were issued to employees and consultants "as an incentive
for
performance" implies that there was intrinsic value above and
beyond
the $.01 per share that was paid for the shares.  Please either
tell
us how you plan to revise your financial statements to reflect the
fair value of this restricted stock issuance, or otherwise, and in
light of all of the above, tell us why you continue to believe it
is
appropriate that you recorded no charge related to this restricted
stock issuance.   Please cite the applicable authoritative
literature
in your response.

*******

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please furnish a letter that keys your response
to
our comments and provides any requested supplemental information.
Detailed response letters greatly facilitate our review.  Please
file
your response letter on EDGAR.  Please understand that we may have
additional comments after reviewing your response to our comments.

      If you have any questions regarding these comments, please
direct them to Staff Accountant David DiGiacomo at (202) 824-5493.
In his absence, direct your questions to Robyn Manuel at (202)
942-
7786.  Any other questions may be directed to me at (202) 942-
2905.

							Sincerely,

							George F. Ohsiek, Jr.
							Branch Chief

??

??

??

??

Mr. James N. Jannello
Chief Executive Officer
Janel World Trade, LTD.
March 22, 2005
Page 1

</TEXT>
</DOCUMENT>