SecProbe.io

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                            JOSEPH GUNNAR & CO., LLC
                                 30 Broad Street
                               New York, NY 10004

                                                     February 11, 2005

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

             Re: Tarpon Industries, Inc. Registration No. 333-120117

Ladies and Gentlemen:

     Pursuant to Rule 460 of the General Rules and Regulations under the
Securities Act of 1933, as amended (the "Securities Act"), we, as representative
of the several Underwriters, wish to advise you that in connection with the
above-captioned Registration Statement, copies of the Preliminary Prospectus
dated February 3, 2005 were distributed as follows:

<TABLE>
<CAPTION>
         Underwriter                        Date(s)                Copies
<S>                                   <C>                  <C>
Joseph Gunnar & Co., LLC              02.04.05 - 02.05.05            550
LaSalle St. Securities Corp.          02.04.05 - 02.07.05            300
Newbridge Securities Corporation      02.04.05 - 02.07.05            250
                                                                  ------

                                                           Total:  1,100
</TABLE>

In accordance with Rule 461 of the General Rules and Regulations under the
Securities Act, we hereby join in the request of Tarpon Industries, Inc. to
accelerate the above-captioned Registration Statement, relating to the offering
of up to 3,277,500 common shares, no par value, of Tarpon Industries, Inc. in
its initial public offering and 758,800 common shares in a subsequent re-sale of
common shares by selling shareholders, so that it will become effective at 10:00
a.m. Eastern time on February 11, 2005 or as soon thereafter as is practicable.

     The underwriters acknowledge that (1) should the Commission or the staff,
acting pursuant to delegated authority, declare the filing effective, it does
not foreclose the Commission from taking any action with respect to the filing,
(2) the action of the Commission or the staff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve the underwriters
from their full responsibility for the adequacy and accuracy of the disclosure
in the filing, and (3) the underwriters may not assert this

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action as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

                                        Very truly yours,

                                        JOSEPH GUNNAR & CO, LLC
                                        REPRESENTATIVE OF THE
                                        SEVERAL UNDERWRITERS

                                        By:    /s/ STEPHAN A. STEIN
                                             ----------------------------
                                               Stephan A. Stein

                                               Its:   Chief Operating Officer
                                                    --------------------------

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