SecProbe.io

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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>generalletter.txt
<DESCRIPTION>ITEM 4.01 FORM 8-K FILED 11/12/04 COMMENT LETTER
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					November 17, 2004

Mail Stop 0409

VIA U.S. MAIL AND FAX 212-407-4990

Mr. Bruce Cole
President
General Components, Inc.
Suite 2021, 20/F, Two Pacific Place
88 Queensway
Hong Kong

RE:	General Components, Inc.
	Form 8-K filed November 12, 2004
            File No. 0-33483

Dear Mr. Cole:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, we will consider your explanation
as to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  In some of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

	Please understand that the purpose of our review process is to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  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.

1. Please revise the Form to state whether the former accountant
resigned, declined to stand for re-election or was dismissed, and the
specific date, as required by Item 304(a)(1)(i) of Regulation S-B.
It is not sufficient to state that the company "ended the engagement"
of the accountant, as that wording is unclear to a reader.

2. Item 304(a)(1)(ii) of Regulation S-B requires a statement whether
the accountant`s report on the financial statements for either of the
past two years contained an adverse opinion or a disclaimer of
opinion or was modified as to uncertainty, audit scope or accounting
principles; and a description of the nature of each such adverse
opinion, disclaimer of opinion or modification.  This would apply to
the report on the financial statements for the fiscal years ended May
31, 2004 and 2003 and would include disclosure of uncertainty
regarding the ability to continue as a going concern in the
accountant`s report.

3. Revise your disclosure to state whether during the registrant`s
two most recent fiscal years and any subsequent interim period
through the date of resignation, declination or dismissal there were
any disagreements with the former accountant on any matter of
accounting principles or practices, financial statement disclosure,
or auditing scope or procedure, which disagreement(s), if not
resolved to the satisfaction of the former accountant, would have
caused it to make reference to the subject matter of the
disagreement(s) in connection with its reports.  This would apply to
the fiscal years ended May 31, 2004 and 2003 and the subsequent
interim period through the date of dismissal.  In the event of
disagreement(s) and/or reportable event(s), provide the specific
disclosures required by Item 304(a)(1)(iv) of Regulation S-B.

4. Please request that the former accountant revise the Exhibit 16
letter.   The letter should be addressed to the Commission and state
whether the former accountant agrees with the statements made in the
Form 8-K and, if not, state the respects in which it does not agree.
Please note that your former accountants should make it clear within
the Exhibit 16 letter that it is in reference to your amended Form 8-
K.

File an amendment under cover of Form 8-K/A and include the ITEM 4.01
designation, including the letter from the former accountant filed as
an Exhibit 16.

We urge all persons who are responsible for the accuracy and adequacy
of the disclosure in the filings reviewed by the staff to be certain
that they have provided all information investors require.  Since the
company and its management are in possession of all facts relating to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* 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.

In addition, please be advised that the Division of Enforcement has
access to all information you provide to the staff of the Division of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

Please provide the supplemental information requested above within 10
business days from the date of this letter.  The supplemental
information should be filed as correspondence on EDGAR.  The
amendment requested should be filed as promptly as possible and
should be reviewed by the former accountants.  The letter required by
Exhibit 16 should cover any revised disclosures.

Any questions regarding the above should be directed to me at (202)
824-5336, or in my absence, to Robert Benton at (202) 942-1811.

						Sincerely,

						Rachel Zablow
						Staff Accountant

General Components, Inc.
November 17, 2004

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