SecProbe.io

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Mail Stop 03-08

								May 5, 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
April 26, 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.

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

Consolidated Financial Statements

Note 1 - Summary of Significant Accounting Policies

Revenue Recognition
1. We read your response to prior comment number 6, along with
your
proposed revision to your revenue recognition policy and it
appears
you have not fully addressed our comment.  Based on your proposed
disclosure, it is our understanding that under arrangements where
you
act as a freight consolidator, you record revenues based on the
gross
amount billed to customers, whereas under arrangements where you
act
as an agent for the shipper, you record revenues based on the net
amount retained as a commission or fee.  Please provide us
supplementally your analysis under EITF 99-19 which supports your
determination to record the freight consolidator revenues on a
gross
basis and certain other revenues on a net basis.  Ensure your
response is clear in terms of the distinguishing features of these
arrangements that result in the differing revenue recognition
methodologies.  Also ensure your response addresses your
consideration of the four items listed in paragraph 3 of EITF 99-
19
as well as each of the indicators of gross versus net reporting in
paragraphs 7-20 of the EITF.  Notwithstanding the preceding,
please
revise your proposed disclosure to indicate the basis in GAAP for
your various revenue recognition methodologies.  Show us how the
revised disclosure will read.
2. With respect to your freight consolidation revenues, please
tell
us your basis for recording revenues at the point of delivery to
the
direct carrier, rather than at the point of delivery to and
acceptance by your customer.  In this regard, it appears to us
that
the earnings process is not complete until you have delivered the
product to the customer.  Please ensure you consider the
provisions
of SAB Topic 13 in crafting your response.  Also, please revise
your
disclosures in future filings to indicate your basis for recording
revenues prior to delivery to and acceptance by the customer.

Note 8 - Stockholders` Equity
3. Based on your response, it does not appear that you are able to
support having recorded no compensation related to the restricted
stock grant.  Thus, please tell us in detail how you plan to
revise
your financial statements accordingly.  In this regard, we note
your
point that the result of the revision of the financial statements
will be an equity reclassification, reducing retained earnings and
increasing additional paid in capital.  However, we note that the
revision will also result in a potentially significant increase in
net losses in the year ended September 30, 2002 and that the
revision
may also substantially reduce or even eliminate your retained
earnings balance.

      In your response, please address for us in detail how you
determined the revised fair value of the restricted stock
issuance,
including the significant assumptions used and the basis for those
assumptions.  Also, to the extent that the fair value you
determine
for the restricted stock is significantly less than the range of
values at which your stock began to actively trade in mid-August
2002, less than one month after the restricted stock grant, please
provide us a detailed chronology of the events that occurred after
the date of grant that resulted in the significant increase in the
quoted market price/fair value of your stock.  Also be advised
with
respect to the restricted shares that were issued to employees
that
APB 25 precludes adjustments to fair value measurements for
restrictions on transferability of the stock.

*******

      As appropriate, please 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) 551-3319.
In his absence, direct your questions to Robyn Manuel at (202)
551-
3823.  Any other questions may be directed to me at (202) 551-
3843.

							Sincerely,

							George F. Ohsiek, Jr.
							Branch Chief

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Mr. James N. Jannello
Chief Executive Officer
Janel World Trade, LTD.
May 5, 2005
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