SecProbe.io

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                             Scheichet & Davis, P.C.
                                Counselors at Law
                          767 Third Avenue - 24th Floor
                               New York, NY 10017
                                 (212) 688-3200
                               Fax: (212) 371-7634

                                                    March 15, 2005

George F. Ohsiek, Jr., Branch Chief
David DiGiacomo, Robyn Manuel
United States Securities and
Exchange Commission
Mail Stop 3-08
450 Fifth Street
Washington, D.C.  20549

                        Re:   Janel World Trade,  Ltd.  Form 10-K for the Fiscal
                              Year Ended September 30, 2004, File No. 333-60608,
                              Filed December 28, 2004

Dear Mr. Ohsiek, Mr. DiGiacomo and Ms. Manuel:

      We are the attorneys for Janel World Trade,  Ltd.  (the  "Company").  This
letter is in response to your February 15, 2005 letter of comment (the "Letter")
regarding the Company's Form 10-K Report for its fiscal year ended September 30,
2004.

      The Company  will be  responsive  to each of the comments set forth in the
Letter.  All page  references are to the page numbering in the EDGAR versions of
the filings being mentioned.

             Form 10-K for the Fiscal Year Ended September 30, 2005
             ------------------------------------------------------

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, 2005, page 15
--------------------------------------

      1. This comment  suggests  revisions to increase the  transparency  of the
underlying  causes of  changes  in  results  so as to  provide  a more  detailed
analysis of material  year-to-year  changes and trends, and to ensure discussion
of each significant change in the line items of the statements of operations.

                                       1
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      The Company will implement the suggested  revisions in future filings.  In
the MD&A of the Company's  Form 10-Q for the first fiscal quarter ended December
31, 2004,  filed  February 16, 2005,  the Company has included  revisions in the
first  paragraph on page 7, under the heading  Three  Months Ended  December 31,
2004  Compared to the Three Months  Ended  December  31,  2003,  discussing  the
reasons  for a  significant  decrease in revenue  during the period;  and in the
discussion of SG&A expense on the top of page 8 focusing on the increase of SG&A
expense  as a  percentage  of  revenue  as  compared  to both the  prior  years'
comparable period and the immediately preceding fourth quarter of fiscal 2004.

Results of  Operations - Fiscal Year Ended  September 30, 2003 Compared to
--------------------------------------------------------------------------
Fiscal Year Ended September 30, 2002, page 17
--------------------------------------------------------------------------

      2. The Company will  emphasize  GAAP income and results of  operations  in
future  filings,  and will provide the requisite  reconciliation  and disclosure
pursuant  to Item  10(e)(A) of  Regulation  S-K  whenever  it presents  non-GAAP
financial information.

Liquidity and Capital Resources, page 19
----------------------------------------

      3. The Company  will  implement  these  suggested  revisions in its future
filings.  As noted above, the MD&A in the last three paragraphs on page 8 of the
Company's  Form 10-Q filed  February  16, 2005  includes an  explanation  of the
significant decrease in both accounts receivable and accounts payable during the
period.  The last  sentence of the second  paragraph  confirms that Janel's past
cash flow performance is generally indicative of future cash flow performance.

      4. The Company's critical  accounting policies have been provided on pages
10 and 11 of the Company's  Form 10-Q filed  February 16, 2005,  together with a
description of the assumptions and uncertainties that underlie those policies.

      5.  Future  filings  will  include a  tabular  discussion  of  contractual
obligations  pursuant to Item 303(a)(5) of Regulation  S-K. In this  connection,
the Company notes that capitalized  lease  obligations  aggregate  approximately
$700 per month, the rental expense on operating leases for the Fiscal Year Ended
September 30, 2004 was $294,000 and that future obligations under non-cancelable
leases are  expected to decline  over the next five years (see Notes 7 and 11 to
the financial statements at September 30, 2004).

Current Outlook, page 20.
-------------------------

      6. Future  filings will include a discussion  of the  estimated  impact of
both the  acquisition  and loss of significant  customers,  such as Ralph Lauren
Childrenswear (this customer lost its Ralph Lauren license,  its annual billings
amounted to approximately $170,000). In this connection, in the second paragraph
under Current  Outlook on page 9 of the Company's  Form 10-Q filed  February 16,
2005, there is a brief discussion of management's review of the profitability of
various  customer  accounts  and its  intention  to  focus  on  more  profitable
accounts,  and the likely  affect of that  process on gross  revenue  during the
fiscal year ending September 30, 2005.

                                       2
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Item 8. Financial Statements and Supplementary Data
---------------------------------------------------

General
-------

      7. The auditors have advised that the Company's valuation accounts related
to allowances for doubtful accounts are not material. The allowance for doubtful
accounts  aggregated  $31,413 at September  30, 2004, or less than 0.5% of total
assets.  In addition,  the write-off of bad debts was immaterial in fiscal 2004,
and  reserves for  depreciation  (accumulated  depreciation)  and the changes in
those accounts are not material. Depreciation expense is separately disclosed in
the Consolidated Statements of Cash Flows.

Independent Auditors' Report
----------------------------

      8. The Form 10-K for 2004 will be  amended to  include  the  signed  audit
report.

Consolidated Statements of Operations
-------------------------------------

      9. In  future  filings  the  line  item  on the  Statement  of  Operations
captioned "freight forwarding revenues" will be changed to "revenues".

      10.  Similarly,  in  future  filings  the line  item on the  Statement  of
Operations captioned "income before other items" will be changed to "income from
operations,"  and the Company will include in income from operations each of the
items referred to in subparagraphs b through d of paragraph 10 of the Letter.

Consolidated Statements of Changes in Stockholders' Equity
----------------------------------------------------------

      11. I am advised that the Company  will,  in fiscal year 2005,  reclassify
$250,000 between retained earnings and additional paid in capital retroactive to
the first period presented. This is expected to have no affect on the net equity
of the Company, but will only be a reclassification between capital accounts.

Note 1 - Summary of Significant Accounting Policies
---------------------------------------------------

General.
--------

      12. I am advised that the disclosures referred to in paragraphs 26, and 37
through 39 of SFAS 131 are not required  for the  Company.  The Company has only
one business segment, a full service cargo  transportation  company, it has only
domestic  offices and has no foreign  locations,  and it has no single  customer
whose  business  accounts for 10% or more of the Company's  revenue (the largest
customer accounts for 6% of revenue).

      13. I am advised that the Company  invoices its customers in U.S.  Dollars
only,  and that  the  aggregate  foreign  exchange  transaction  gain or loss is
insignificant.  If  applicable,  the Company's  future filings will disclose the
aggregate  foreign exchange  transaction gain or loss included in net income for
each period presented. Cash and Cash Equivalents

                                       3
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Cash and Cash Equivalents
-------------------------

      14.  In  future  filings,  the  Company  will  revise  its  Cash  and Cash
Equivalents  policy to disclose the nature and maturity of its cash equivalents,
and will revise the related  caption in the balance  sheet to indicate  that the
line item represents both cash and cash equivalents.

Revenue Recognition
-------------------

      15. In future  filings,  the Company  will revise its revenue  recognition
policy  to  clearly  describe  each of its  revenue  generating  activities  and
separately  explain its revenue  recognition  policy for each material source of
revenue.  Attached to this  letter as  supplemental  information  is Schedule A,
which contains the proposed revision to the revenue recognition policy.

Note 6 - Note Payable - Bank
----------------------------

      16. There are no covenants  associated with the Company's bank borrowings.
Any future covenants will be disclosed.

Note 8 - Stockholders' Equity
-----------------------------

      17. On July 22, 2002,  the market price of the Company's  publicly  traded
common stock on the OTC Bulletin Board was $.01 per share,  with no transactions
in the stock for a  considerable  period of time  prior to the date.  The shares
sold to employees and consultants on that date for a purchase price of $0.01 per
share were vested upon  issuance and  restricted  from sale for one year.  Based
upon the price quotations listed by the various broker/dealer market makers, and
in view of the  restriction  on  resale  for at  least  one  year,  the  Company
concluded that the fair value of the restricted stock as of the date of sale was
approximately  $.007 per share.  It  therefore  set the sale price at the market
price.

      The  Company  concluded  that  there was no  impact  from that sale on its
financial  statements  and  statements of  operations  because the employees and
consultants  who purchased the stock did not pay less than fair market value for
their  shares.  There were no issuances of shares of common stock by the Company
to unrelated parties at that time.

Item 9A. Controls and Procedures.
---------------------------------

      18. The  disclosure  in this  section,  on page 12 of Company's  Form 10-Q
filed February 16, 2005, was corrected as suggested, and that disclosure will be
continued in future filings.

      19.  There  have been no  changes  in  internal  controls  over  financial
reporting identified in connection with the evaluation required by paragraph (d)
of  Exchange  Act Rules  13a-15 or 15d-15 that  occurred  during the most recent
fiscal  quarters  which has  materially  affected,  or is  reasonably  likely to
materially affect, the internal controls over financial reporting. Exhibits 31.1
and 31.2  have been  appropriately  revised  in the  Company's  Form 10-Q  filed
February 16, 2004, and these revisions will continue in future filings.

                                       4
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Exhibit 31-Section 302 Certifications
-------------------------------------

      20.  As  noted  above,  Exhibits  31.1 and 31.2  have  been  appropriately
revised,  together  with the  disclosure  set  forth in Item 4 on page 12 in the
Company's Form 10-Q filed February 16, 2004.

      As discussed in my telephone conversation with Robyn Manuel, the filing of
the amendment to the Company's  Form 10-K for the Fiscal Year Ended 2004 will be
made as promptly as possible  after the Company  receives  the staff's  reply to
this response letter.  Upon request,  marked copies of the amendment to the 10-K
will be separately supplied to the staff.

      The Company's management  appreciates the attention and cooperation of the
staff with regard to this matter,  and we look forward to hearing any additional
comments or concerns as soon as possible.

                                                 Very truly yours,

                                                 SCHEICHET & DAVIS, P.C.

                                                 William J. Davis

cc:  James N. Jannello, President
     Janel World Trade Ltd.

     Brian Serotta and Robert Nowakoski,
     Paritz & Company, P..A.

                                       5
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                                   SCHEDULE A

REVENUES AND REVENUE RECOGNITION

      Airfreight,  ocean freight and custom  brokerage  services revenue include
the charges to the Company for carrying  the  shipments  and customs  clearance.
Revenues  recognized in other  capacities  include only the commissions and fees
earned and are recognized upon completion of the services.

      Revenues  related  to  export  shipments  are  recognized  at the time the
freight is tendered to a direct  carrier at origin.  Revenues  related to import
shipments are recognized upon  presentation of the entry for customs  clearance.
All  other  revenues,   including  break-bulk  services,  local  transportation,
distribution services and logistics management, are recognized upon performance.
Revenues  from all  categories  are  recorded  on a gross  basis as is  standard
industry practice.

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