SecProbe.io

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August 3, 2005

MAIL STOP 3561

via U.S. mail and facsimile

Michael L. Metter, President
Spongetech Delivery Systems, Inc.
1350 Broadway, Suite 210
New York, NY  10018

Re:      Spongetech Delivery Systems, Inc.
	Form SB-2, Amendment 2 filed July 5, 2005
	File No. 333-123015
Supplement to comment letter dated August 1, 2005

Dear Mr. Metter:

	As a supplement to our comment letter dated August 1, 2005,
we
have the following accounting comments on your filing. 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.

General
1. Include a currently dated consent of the independent auditor
with
any amendment to the registration statement.  You should also
update
the financial statements through May 31, 2005.  Refer to the
updating
requirements of Item 310(g) of Regulation S-B.

Financial Statements
Note 6 - Contingencies, Page 12

2. Revise to provide full disclosure concerning the Westgate
litigation.  We note the disclosure in Legal Proceedings on page
19
concerning the default judgment and counterclaim.  In addition,
provide management`s assessment of the effect of an adverse
outcome
in terms of the financial statements taken as a whole.  Refer to
SFAS
5 and SAB Topic 5.Y.

Closing Comments

As appropriate, please amend your registration statement in
response
to these comments.  You may wish to provide us with marked copies
of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	You may contact Donald Wiland at (202) 551-3392 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact Susann Reilly at (202) 551-3236 with
other
questions.

Sincerely,

John Reynolds
Assistant Director
Office of Emerging Growth Companies

cc:  David Schiff, Esq.
By facsimile (212) 930-9725

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Michael L. Metter, President
Spongetech Delivery Systems, Inc.
August 3, 2005
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