SecProbe.io

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Mail Stop 3561

July
14, 2005

John A. Fahlberg, President
New Age Translation, Inc.
12926 Morehead
Chapel Hill, N.C.  27517

RE:  New Age Translation, Inc. ("the company")
        Registration Statement on Form SB-2
        Filed June 7, 2005
        File No. 333-125575

Dear Mr. Fahlberg:

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.

General

1. Your disclosure indicates that you are a development stage
company
that intends to provide English to Chinese and Chinese to English
translation services. However, your disclosure shows that your
operations have been primarily limited to building a building a
business plan, with no operating history, no revenues, no
contracts
or agreements with clients, your sole officer and director has no
prior experience in translation services, your sole officer and
director will devote limited time to the operations this is a
selling
shareholder offering and the company will not receive any
proceeds,
company has no financing arrangements or commitments, and a need
to
develop your web site to provide more informational services. In
view
of the foregoing, we believe that your proposed business may be
commensurate in scope with the uncertainty ordinarily associated
with
a blank-check company.  Please revise your registration statement
appropriately to provide a more detailed plan of operations and
milestones in your "Plan of Operations" section.  In the
alternative,
revise to disclose the blank check nature of the company and your
offering and to comply with the provisions of Rule 419.

2.      Please consider the circumstances under which the
company`s
securities may be issued to management, promoters or their
affiliates
or associates, and amend or advise accordingly.  We note the large
amount of authorized but unissued common stock, which may be
issued
without further shareholder approval or notice.

Prospectus Cover Page

3. Please revise the prospectus cover page to state the offering
period for the sale of the shares being offered.  Also, if there
is
any potential extension in the offering period, this should be
made
clear.

4. It is suggested that the language in paragraph three (3) be
revised to state that the shares are not listed and traded on any
stock exchange.  Please refer to Item 501(a)(4) of Regulation S-B
in
this regard.

5. Referring to the bold-face language in the penultimate
paragraph,
please revise and provide the standard language as set forth by
Item
501(a)(7) of Regulation S-B.

Summary of Our Offering

Our Business, page 5

6. In the Business - Services section, please indicate
specifically
how, through what means, you will provide English to Chinese and
Chinese to English translations.

Selected Financial Data, page 5

7. This information should be updated to the latest date
practicable.

Risk Factors, page 6

8. We note the disclosure in the second (2nd) risk factor that
"our
ability to achieve and  maintain profitability and positive cash
flow
is dependent upon the completion of this offering".   Elsewhere in
the filing we note the following disclosure "we will not receive
any
proceeds from the sale of shares of common stock in this offering.
All proceeds from the sale of the shares of common stock will be
received by the selling shareholders".  Please revise and advise.

9. We note the statement in your fourth (4th) risk factor that you
have "just initiated our operations."  Inasmuch as the company has
solely received funds from a private placement of stock, your
further
reference to "...we will have to cease operations" appears
inappropriate and should be revised/deleted.

10. Referring to the seventh (7th) risk factor, it would appear
that
the company will have to hire an additional person(s) with
specific
experience in this type of service.  Please revise.
11. We note risk factor #7 that Mr. Fahlberg does not have prior
experience in the translation services.  Please disclose the
extent
in which Mr. Fahlberg speaks Chinese.

Determination of Offering Price, page 8

12. Please provide more specificity regarding how the price was
selected.  The reference to "our board of directors" appears to
mean
one person, Mr. Fahlberg.  Please clarify.

Plan of Distribution, page 9

13. In the second full paragraph, please make clear that there is
no
assurance of when if ever, the shares will become traded on the
Bulletin Board or another exchange.

Business

General, page 12

14. Indicate the arrangements between the company and Mr. Fahlberg
for providing office space.  If this is an informal arrangement,
this
should be mentioned, or if there is an executed lease agreement,
please so indicate and file the agreement as an exhibit to the
registration statement.
15. Revise the second paragraph and the reference to "limited
operations".

Services, page 12

16. We note the services the company intends to provide as
outlined
in the three paragraphs.  Considering the fact that the company`s
one
employee has no experience in these areas, and this one employee
will
only devote a minimal amount of time to the company`s business
please
explain how these services will be provided.

Industry

17. Indicate whether or not the company has plans to join the ATA
organization and whether it has made contact with it to provide
help
as contemplated.

18. The basis for the statements made in paragraph two should be
made
clear.

19. At the end of the third paragraph, please clarify the Ohio
University Department of Linguistics` qualifications regarding its
knowledge and authority of the Chinese language.

Our Planned Operations, page 13

20. Clarify the basis for your initial statement or delete it.

21. State if the company has plans to purchase the translation
memory
software mentioned in the last paragraph and its cost.

Marketing, page 15

22. We note that the company has not conducted any market studies
or
surveys.  Please briefly explain the proposed effectiveness of
your
"marketing practices" without any background knowledge in that
regard.

23. We note that the company intends to "promote our services on
our
website."  Please clarify "[T]he website will not be used to
generate
revenues."

24. In a separate section, please address the company`s plans for
its
website in some detail.  If one is in the development stage,
please
provide the website address and discuss the current status, costs
to
produce and maintain, etc.

Competition, page 16

25. The last paragraph is duplicative of one in another section.
Please delete.

Management`s Discussion and Analysis...

Plan of Operations, page 17

26. Revise the third paragraph to disclose an estimate of the
amount
the company plans to initially spend on its computer equipment and
the establishment of its website.
27. We note in item 2. that you have "contacted an outside web
designer to begin development of the website."  Please provide
more
detail and the current status.  If any agreement has been entered
into, please identify the web designer, outline the material terms
of
the agreement and file the contract as an exhibit to the
registration
statement as required by Item 601 of Regulation S-B.

28. Please revise to accurately and consistently discuss the
amount
of proceeds the company will have to fund its operations for at
least
one year.  For example, we note on page 16, "we raised $81,400
proceeds and net proceeds of $46,500" which amount will fund
operations for one year.  According to the Liquidity and Capital
Reserves on page 17 we note "$81,400 was raised and we have spent
$900.00.  We believe that the money will last at least a year."
Please advise and revise.

29. According to Part II Other Expenses of Issuance and
Distribution,
we note the total expense of $35,000.00.  Please provide a
footnote
to the table to disclose if true that a portion of the expense has
been paid.  For example, Note #5 to the financial statements
reflect
that $15,000.00 for legal fees have been paid and the remaining
$10,000.00 will be due when the registration statement is declared
effective.  In addition, please note the disclosure in the Certain
Transactions section on page 25 that Mr. Fahlberg has advanced
$18,565.00 to the company for expenses incurred in connection with
our incorporation, accounting and auditing fees and preparation of
this registration statement. Please revise the filing to disclose
the
amount of funds the company will require and amount of funds
available for the next 12 months.

Liquidity and Capital Resources, page 18

30. Please update the dollar amount of total assets and
liabilities
to a more recent date.

Management, page 19

31. Please advise if Mr. John Fahlberg has been or is associated
and
in what capacity with "The Atlantis Group, LLC, in Durham, NC
during
the past five years.

Conflicts of Interest, page 20

32. Please expand the disclosure to identify the projects in which
Mr. Fahlberg is involved and that may involve a potential conflict
of
interest.

Executive Compensation, page 21

33. We note that the company does not plan to pay Mr. Fahlberg
"until
we begin generating revenues."  Please clarify whether there will
be
any minimum revenue level to be attained and any salary
arrangements.

Selling Shareholders, page 23

34. Please clarify through a footnote the natural person,
beneficial
owner of the shares of  J. Beck & Company.

35. We note that "all purchasers have a preexisting relationship
with
us."  Please explain.
36. Please revise the list of selling shareholders in alphabetic
order and provide the address for each.
37. We note that several of the selling security holders in this
registration statement appear as selling security holders in LDG,
Inc. another registration statement filed by Conrad Lysiak.
Please
explain the appearance of these individuals in this and other
registration statements.  For example, please explain how and by
whom
these selling security holders were identified and brought
together
in these transactions and describe the connections, relationships
and
arrangements between them.  We may have further comments after
reviewing your response.
38. Please provide a description of Mr. Lysiak`s role in
connection
with the formation of New Age Translation, Inc. and the initial
offering(s) of all its securities.  We may have further comments.

Reports, page 24

39. Please revise to provide the new address of the SEC`s Public
Reference Room.  That address is 100 F Street, N.E.,  Room 1580
Washington, D.C.  20549.

Certain Transactions, page 25

40. We note the disclosure in the second paragraph and also that
in
Note 4 - "Related Party Transactions" to the financial statements.
Please expand to add the disclosure from Note 4 and provide the
current status of obtaining the "permanent office in the near
future."

Recent Sales of Unregistered Securities, page 49

41. We note the reliance upon Rule 506 of the Securities Act of
1933
as an exemption from registration for issuance to 53 persons.
Disclose the facts and circumstances relied upon to make the
exemption available for each transaction.  See Item 701 of
Regulation
S-B.

42. In addition please explain the disclosure "all purchasers had
a
preexisting relationship with us".

Financial Statements

43. Please note the updating requirements for the financial
statements as set forth in Item 310(g) of Regulation S-B, and
provide
a current consent of the independent accountants in any amendment.

General

44. Please update the information throughout the prospectus to the
latest date practicable.

45. In the amendment to be filed, please insure that a red-lined
copy
of the amendment is filed on EDGAR as well as the correspondence,
as
required by Regulation S-T.

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
provide 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.

    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
for
an informed decision.  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.

     Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

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;

the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

the company may not assert this action as 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 connection with our review of
your
filing or in response to our comments on your filing.

     We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

We direct your attention to Rules 460 and 461 regarding requesting
acceleration of a registration statement.  Please allow adequate
time
after the filing of any amendment for further review before
submitting a request for acceleration.  Please provide this
request
at least two business days in advance of the requested effective
date.

 Please contact Blaise Rhodes at (202) 551- 3774 with any
questions
regarding  accounting issues and you may contact Janice McGuirk at
(202) 551-3395 with any other questions.

Sincerely,

John Reynolds

Assistant Director

Office of Emerging Growth Companies

CC:   Conrad C. Lysiak, Esq.
         Via fax  (509) 747-1770

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