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

                                                                October 11, 2005

David DiGiacomo
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, Filed December 28, 2004,D
                  File No. 333-60608; Form 10-Q for the Quarterly Period Ended
                  December 31, 2004, Filed February 17, 2005

Dear Mr. DiGiacomo:

      I am the attorney  for Janel World  Trade,  Ltd.  (the  "Company").  As we
recently  discussed  in our  telephone  conversation  last week,  this letter is
intended to expand upon my July 14, 2005  discussion  of the "fair value" issues
raised in the staff's March 22, 2005 comment letter  regarding  certain elements
of the Company's  Form 10-K Report for its fiscal year ended  September 30, 2004
which require amendment.

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

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

      With  respect  to  the  Janel's   authorization   of  the  July  22,  2002
transaction, in which 1,800,000 shares of its unregistered common stock was sold
to  employees  for a price  of $.01 per  share,  the  Company  will  revise  its
estimation of the fair value of the restricted stock issuance as described below
from $.01 per share to $.15 per share.

      The assumptions used and the basis for those assumptions, are as follows:

      A.    There had never  been an active  trading  market  for the  Company's
            shares  of common  stock up until  after  the  authorization  of the
            transaction.

      B.    The  transaction  was  intended  to be  an  incentive  for  employee
            performance,  in  the  expectation  that  Janel's  future  financial
            results  would  improve over time and would result in an increase in
            the market value of its shares of common stock.

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      C.    At the  time  of the  transaction,  a  reasonable  price  per  share
            multiple for Janel's  shares would not exceed 10 times earnings in a
            liquid  market,  given the very low  margins  generated  by  Janel's
            business  at the  time,  as  compared  to the far  more  substantial
            revenues and margins generated by its competitors,  ranging from the
            most comparable competitor,  Target Logistics,  Inc. (symbol: TARG),
            to Expeditors International of Washington,  Inc. (symbol: EXPD), one
            of the  largest  and  most  profitable  competitors  in the  freight
            logistics market segment.

      D.    Target's fiscal year end June 30, 2002 financial statements reported
            approximately   $93mm  of  annual  revenue  and  12,179,000   shares
            outstanding,  a 32%  margin,  a loss of  ($934,527)  and  EBITDA  of
            $598,270,  or $.05 per share.  For its first quarter ended September
            30, 2002, it had a margin of 31%, reported a loss of ($452,709),  or
            $.04 per share, and had an EBITDA of ($186,976), or $.015 per share.

      E.    The Company's June 30, 2002 financial statements reported 15,000,000
            shares  outstanding  and  earnings per share of $.00429 and $.00289,
            respectively,  for the nine and three month  periods then ended.  At
            the fiscal year end of  September  30,  2002,  it reported  $40mm of
            annual revenue, a loss per share of ($.0077),  EBITDA of $90,182, or
            $.06 per share, and a book value of $.15 per share.

      F.    Janel  had  margins  of only  13%  and  11%,  respectively,  for the
            nine-month and  three-month  periods,  and 12.98% for the year ended
            September 30, 2002.

      G.    Target's  stock during the period of June 30, 2002 to September  30,
            2002 was  priced  from a high bid of $.49 per  share to a low bid of
            $.14 per share.  During the July 19 - August 15, 2002 period, it was
            priced between $.30 and $.16 per share,  mostly at $.18 - $.16, in a
            relatively  low volume  market.  Even though  Target had margins and
            revenue  more than twice that of Janel,  its stock price  during the
            period was in the same range as the estimated fair value which Janel
            intends to use in its amended Form 10-K for fiscal 2002 with respect
            to the shares issued in the July 22, 2002 transaction.

      The Company  believes  that the  apparent  pricing of Janel  shares in the
over-the-counter  market in July, August and September 2002 was more likely than
not the result of  manipulative  activities  related  to the  efforts of persons
holding the shares of Wine Systems  Design,  Inc. (the public company into which
Janel merged in reverse acquisition transaction), constituting approximately 28%
of  the  post-acquisition  issued  and  outstanding  shares,  in  an  effort  to
profitably dispose of their shares in the wake of the reverse acquisition.  This
belief is based upon the initial  post-transaction  bid price quotation of $4.00
per share (an absurd P/E of appx. 1,000), with a subsequent sale of 4,700 shares
on July 25, 2002 at $3.75 per share (an equally absurd price), followed by weeks
of  additional  transactions  at  declining  prices down to $1.00 per share (P/E
appx. 250) and below.

<PAGE>

      The  absurdity  of the  "market"  price of Janel's  shares at that time is
highlighted by the market for the shares of  Expeditors,  with annual revenue of
appx.  $1.9b in 2001 and $2.3b in 2002,  net  income of appx.  $97mm in 2001 and
$112mm in 2002, and a cash dividend of $.12 per share.  Expeditors traded at $25
- $29 per share during the July - September  2002 period,  with a P/E between 23
and 27. The Company believes that the market activity in Janel shares around the
time of the  transaction  at P/E  levels  1,000%  more  than  Expeditors  had no
reasonable  relationship to "fair market value," and could only be the result of
blatant over-pricing which was unrelated to a fair market.

      Janel's annual revenues have since  increased from $40mm to  approximately
$70mm with  earnings  of $.015 per share,  and its most  recent  10-Q filing and
press releases indicate further growth in both net income and gross margins, yet
the market price remains in a range of appx. $.45 - $.65 per share.

      The Company has  concluded  that in view of (a) the  unreliability  of the
July - September  2002 market for its shares as an indicator of fair value,  (b)
its low  revenues  and  margins  before,  during  and  after  the  period of the
transaction as compared to those of its competitors,  (c) its reported  earnings
per share  during that  period of $.00429  and  $.00289  per share,  and (d) its
fiscal  year end  September  30,  2002  earnings  per share of $.0077,  the most
appropriate indicator of a revised estimate of fair value would be the Company's
book value at fiscal year end of $.15 per share.

      The  Company  has  decided  that the  compensation  expense it will record
during the period should total $252,000,  reflecting the $.14 spread between the
price paid by the purchasing employees, and its revised estimate of value.

      The Company  expects to file its  amended  Form 10-K/A for the fiscal year
ended  September  30,  2004 after  October  15,  2005,  on or before the seventh
business day after it has been advised that the staff has completed its comments
with respect to the issues it has raised in this exchange of correspondence, and
will thereafter make appropriate adjustments to its filings.

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

                                             Very truly yours,

                                             SCHEICHET & DAVIS, P.C.

                                             /s/ William J. Davis

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

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