SecProbe.io

September 2, 2010
 Mark Meller Chief Executive Officer 5 Regent Street Livingston, New Jersey 09039
Re: Trey Resources, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2009
Filed March 31, 2010 File No. 000-50302

Dear Mr. Meller:
 We have reviewed your filing and have the following comment.  In our comment, we
may ask you to provide us with informati on so we may better understand your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comment applies to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2009

 Consolidated Financial Statements

 Report of Independent Registered Public Accounting Firm, page F-4

1. We note that your Form 10-K contains a copy of the previously issued report of your
predecessor auditor Bagell, Josephs Levine & Company, LLC (“Bagell”) and that Bagell
has not reissued their report.  The inclusion of a copy of a report in this manner does not
comply with Rule 2-02 of Regulation S-X.  Accordingly, the company should either:

• Request that Bagell provide the company w ith a report that complies with Rule 2-
02 of Regulation S-X and that the company file an amendment to Form 10-K with
the revised report, or

 Mark Meller Trey Resources, Inc. September 2, 2010 Page 2
• Obtain a report on the financial statemen ts for the period audited by Bagell from a
new firm that is registered with the PCAOB.   In this situation, as soon as possible,
the company should file an amendment to Form 10-K to label the financial
statements as unaudited and hire a new accounting firm.  Upon completion of the
audit, the Company would need to file another amendment to Form 10-K to file
the appropriate report.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 responding to our comment, please provide a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments 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 federa l securities laws of  the United States.

You may contact Morgan Y oungwood at (202) 551-3479 if you have questions regarding
comments on the financial statements and relate d matters.  Please contact me at (202) 551-3730
with any other questions.
Sincerely,

Stephen Krikorian Accounting Branch Chief