SecProbe.io

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<TYPE>CORRESP
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<FILENAME>filename1.txt
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                         S.E. ASIA TRADING COMPANY, INC.

                              1545 E. Interstate 30
                              Rockwall, Texas 75087
                                 (972) 722-3300

November 9, 2004

Mr. Pradip Bhaumik
Ms. Ellie Quarles
Mr. H. Christopher Owings
U.S. Securities & Exchange Commission
450 Fifth Street NW
Washington, DC 20549

RE:      S.E. Asia Trading Company, Inc.
         Form SB-1
         File No. 333-118898

Dear Mr. Bhaumil, Ms. Quarles and Mr. Owings:

Following are responses to your comment letter dated October 6, 2004.

FACING PAGE
-----------
1.       The address of our principal place of business is included on the cover
         (facing) page of the Registration Statement.

         The four paragraphs set forth in the facing page of Form SB-1 have been
included.

         A  sentence  has been  added to comply  with Rule 415 to state that the
         securities are being offered on a delayed or continuous basis.

PROSPECTUS INSIDE COVER PAGE
----------------------------
2.       The statement  regarding "a full service mortgage company" was included
         in error. The statement has been changed to reflect our correct line of
         business. (Page 1)

3.       A  statement  has been  added that Mr.  Miller  will sell stock in this
         offering  "after the effective  date of this  registration  statement".
         (page 1)

4.       We intend to file for a listing to trade.  A  statement  to  disclosing
         this has been added. (Page 1)

5.       The offering expense per share has been changed. (Page 1)

PROSPECTUS SUMMARY
------------------
6.       We  have  disclosed  that  we have a going  concern  opinion  from  our
         auditors as well as disclosing the losses to date. (Page 2)

7.       The  discussion  of the  business has been  expanded in the  Prospectus
         summary section and the Business Section (Page 2 and page 11)

<PAGE>

8.       The page number  which the Plan of  Operations  begins has been changed
         (Page 2)

9.       The figures in the Summary  Financial  Data have been  changed to agree
         with the numbers in the latest financial statements (Page 3)

RISK FACTORS
------------
10.      We have stated that we have  identified  all  material  risks that were
         known or anticipated (Page 4)

11.      The risk factor  headings  have been  revised a precise  nature of harm
         (risk factors - pages 4 - 5)

12.      We have included a risk factor that our common stock will be treated as
         a penny stock (page 6)

13.      The risk factor that "We are a newly  formed  company......."  has been
         revised to include a statement  about our  qualified  opinion  from our
         auditors (page 4)

14.      The time our  business  will  continue  if we cannot  sell the  minimum
         offering  had  been  disclosed  (risk  factor  "We may  have  to  raise
         additional capital ......" (Page 4)

15.      We have identified all countries from which we purchase  merchandise in
         the risk factor "We are  dependent  on the low cost of foreign  imports
         ........." (Page 5)

16.      Our main local  competitors have been identified in the risk factor "We
         may not be able to compete successfully ........." (Page 5)

17.      This statement has been removed

DILUTION
--------
18.      The numbers  throughout  the document have been changed for updating to
         September 30, 2004 numbers and consistency (page 6 - 7)

19.      A  reconciliation  of the book value on  September  30,  2004  (updated
         figures)   to  the   projected   minimum   and   maximum  is   attached
         supplementally - see attached page.

PLAN OF DISTRIBUTION, PAGE 8
----------------------------
20.      The language has been changed as you  suggested.  In addition,  we have
         removed the sentence  that our  attorney  may  purchase  shares in this
         offering which was included in the section "Relationship With Issuer of
         Experts  Named  in  the  Registration  Statement"  since  it  could  be
         misleading  since we have no  agreements  of any  kind,  even  with our
         attorney.
         (Page 8)

21.      The Rule 3a4-1(a) of the  Securities  Exchange Act has been referred to
         (page 8)

22.      We determined  the easiest and most cost  effective way for the company
         to handle the funds  received in this offering is to collect the checks
         and have our attorney  hold them in his safe until we reach the minimum
         subscription at which time we will deposit them in our bank account and
         retain the  transfer  agent who will then issue the shares.  We came to
         this  determination  for the following  reasons:  (i) A bank charges us
         fees for the escrow account (ii) The minimum subscription is relatively
         small and we should be able to have it subscribed within a short period
         of time (60 - 90 days),  (iii) if we do not deposit the checks until we
         raise the minimum

<PAGE>

         subscription  amount, there is no interest earned and therefore no need
         to pay  interest  on the funds to the  investors,  and (iv) there is no
         opportunity to commingle the funds. (Page 9)

23.      We have clarified when the transfer agent will be retained (page 9)

USE OF PROCEEDS
---------------
24.      The  costs of the  offering  have been  reconciled  and now agree to be
         $16,564 and $33,564 (page 9)

25.      The use of proceeds for the minimum now sum to $75,000 (page 9)

DESCRIPTION OF BUSINESS
-----------------------
26.      The dollar volume of inventory has been disclosed (page 11)

27.      The issue of insurance has been addressed (page 14)

BUSINESS STRATEGY
-----------------
28.      The statements referred to have been revised (page 11)

29.      We have discussed the four "keys to retailing" (page 11)

30.      Our new store plans have been disclosed (page 11 - 12)

31.      We have elaborated on the terms  "strengthen"  and "utilizing  existing
         and planned distribution infrastructure" (page 11 - 12)

METHOD OF DISTRIBUTION OF PRODUCTS AND SERVICES
-----------------------------------------------
32.      We have  deleted the  description  "bedroom  community"  and used other
         descriptions (page 12)

MERCHANDISING AND MARKETING
---------------------------
33.      This sentence has been deleted (page 13)

34.      The total amount we have spent on promotion  has been  disclosed  (page
         13)

COMPETITION
-----------
35.      We have deleted the comment "uniquely positioned in the marketplace"

36.      This  statement has been deleted since we have only one employee  (page
         14)

MANAGEMENT'S DISCUSSION AND PLAN OF OPERATIONS
----------------------------------------------
37.      This  section  has  been  expanded  to  discuss   material  trends  and
         uncertainties (page 15)

38.      We have added a detailed  discussion  of our ability to  generate  cash
         flow for the next 12 months (page 15)

39.      We have described how the minimum proceeds would finance our operations
         for a year (page 15)

40.      We have identified the financing  company and filed the agreement as an
         exhibit (page 15)

DESCRIPTION OF PROPERTY
-----------------------
41.      We have revised this section to state that we signed a three year lease
         (page 16)

<PAGE>

REMUNERATION OF DIRECTORS AND OFFICERS
--------------------------------------
42.      We have  disclosed the  approximate  fair market value of Mr.  Miller's
         services (page 17)

43.      Mr.  Miller  received 4.5 million  shares for  services,  which was his
         remuneration.  He  also  purchased  500,000  shares  for a  total  of 5
         million.  Thus, in the other  references  throughout  the document to 5
         million shares, it is regarding his total holdings.

44.      This  section  has been  revised to state  that Mr.  Miller is the only
         person paid (page 17)

PRINCIPAL SHAREHOLDERS
----------------------
45.      Shareholders of 5% or more are included in this section (page 18)

SECURITIES BEING OFFERED
------------------------
46.      Information  as of the most recent  practicable  date is included (page
         19)

CAPITALIZATION
--------------
47.      The numbers  have been updated for the  September  30, 2004 numbers and
         agree with the updated financial statements (page 21)

ITEM 4.  UNREGISTERED SECURITIES ISSUED OR SOLD WITHIN ONE YEAR
---------------------------------------------------------------
48.      The reference to July 1999 was in error, it has been changed to January
         2004.

49.      All persons to whom securities were issued have been disclosed.

SIGNATURE PAGE
--------------
50.      The exact language required by Form SB-1 has been included.

51.      The date Mr. Miller signed the registration statement has been added.

FINANCIAL STATEMENTS, PAGE F-1
------------------------------
52.      The financial statements have been updated to September 30, 2004 and an
         updated consent filed as an exhibit

BALANCE SHEET, PAGE F-2
-----------------------
53.      The line item "Line of Credit" has been revised to indicate  that it is
         with a related party.

NOTE 1 - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES
---------------------------------------------------
54.      The  nature  of the  business  is  referred  to in the note one  titled
         "Summary of Significant Accounting Policies"

55.      The  types  of  expenses  in the  'cost  of  sales'  and  'general  and
         administrative' categories have been identified

56.      The revenue recognition policy has been expanded

57.      The computation of net loss per share has been disclosed

58.      Our  policy  for  classifying   shipping  &  handling  costs  has  been
         disclosed.

<PAGE>

NOTE 2. FINANCIAL CONDITION AND GOING CONCERN
---------------------------------------------
59.      This note has been expanded.

NOTE 4. LINE OF CREDIT

60.      We have  described how we accounted for the Line of Credit  transaction
         which was not clear before.  We sold 400,000 shares for $20,000 cash in
         conjunction with obtaining the line of credit. None of this $20,000 was
         expensed.

NOTE 5. COMMON STOCK
--------------------
61.      The fair  value of the  services  has been  disclosed  and the  expense
         recorded in the financial statements

62.      The rights and privileges of the securities has been disclosed

EXHIBITS
--------
63.      The Exhibits have been renumbered

Please call me if you need any further clarification on any of these answers.

Sincerely,

/s/ Thomas G. Miller
--------------------
Thomas G. Miller
President

<PAGE>

<TABLE>

<CAPTION>

S.E. ASIA TRADING COMPANY, INC.
Dilution for IPO
                                       Sept 30       Increase       Increase
                                        2004          Minimum        Maximum         Minimum         Maximum
------------------------------------------------------------------------------------------------------------------
<S>                                                                                  <C>             <C>

Cash                                      1,060.00     58,436.00      466,436.00       59,496.00       467,496.00
Inventory                                63,662.00                                     63,662.00        63,662.00
Marketable securities                         0.00                                          0.00             0.00
                                                                                            0.00             0.00
Equipment                                20,656.00                                     20,656.00        20,656.00
Accum depreciation                       (2,074.00)                                    (2,074.00)       (2,074.00)
Deposits                                  3,255.00                                      3,255.00         3,255.00
                                                                                            0.00             0.00
A/P                                           0.00                                          0.00             0.00
Accrued expenses                         (4,892.00)                                    (4,892.00)       (4,892.00)
LOC payable                             (90,612.00)                                   (90,612.00)      (90,612.00)
                                                                                            0.00             0.00
Note payable                                                                                0.00             0.00
                                                                                            0.00             0.00
Common stock                             (6,020.00)      (150.00)      (1,000.00)      (6,170.00)       (7,020.00)
Paid in capital                        (100,980.00)   (58,286.00)    (465,436.00)    (159,266.00)     (566,416.00)
R.E.                                    115,945.00                                    115,945.00       115,945.00

Total capital                             8,945.00                                    (49,491.00)     (457,491.00)

                                              0.00          0.00            0.00            0.00             0.00

# shares o/s                             6,020,000       150,000       1,000,000       6,170,000        7,020,000
Book value                                   8,945                                       (49,491)        (457,491)
Book value per share                        0.0025                                         (0.01)           (0.06)

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