SecProbe.io

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Mail Stop 3561

November 2, 2005

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

              RE:  New Age Translation, Inc. ("the company")
                      Amendment No. 1 to Registration Statement on
                      Form SB-2
                      Filed September 29, 2005
                      File No. 333-125575

Dear Mr. Fahlberg:

We have reviewed your amended 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. We note counsel`s response to our prior comment 1.  If true,
please disclose that the company does not consider itself to be a
"blank check" company as that term is defined in Rule 419 of
Regulation C and that you do not intend to merge with or be
acquired
by another company in the foreseeable future.

John A. Fahlberg
      New Age Translation, Inc.
      November 2, 2005
      Page 2.
2. We note several references to "...we intend..."  For example,
in
the section "Planned Operations", "We intend to purchase this
software."  Under the section "Marketing", "We intend to promote
our
services on our website."  "We intend to establish our office and
acquire the equipment..." Also, we note that the company has
contacted the ATA but has not paid the fee to join.  Inasmuch as
you
state in your response to our prior comment 1 that the company has
"adequate funds to begin operations" why haven`t these things been
accomplished to date?  Please advise.

Prospectus Cover Page
3. Explain your reference to "another exchange."
4. Please remove the table at the bottom of the cover page.  Such
information is not required by Item 501 of Regulation S-B for this
offering.

Business

Services, page 12
5. Considering the fact that the company`s one employee, Mr.
Fahlberg, has no prior experience in this area and no industry
contacts, please explain how the company will "promptly hire a
translator" as soon as the company gets its first client. Please
explain how this is a realistic plan for the company.  We may have
further comment.

Plan of Operation, page 17
6. We note your initial statement in the fifth (5th) paragraph,
"[O]ur specific goal is to begin website development, assembling a
client database and establishing an office ..." followed by your
milestones.  The first milestone states, "[W]e intend to establish
our office..."  We further note the second milestone, "[W]e have
established our office.  Our website was designed by Dan Allison,
a
website designer."  Please revise your initial statement and
delete
the initial milestone, accordingly, to make the disclosure
consistent.

John A. Fahlberg
New Age Translation, Inc.
November 2, 2005
Page 3.

7. With respect to the third milestone, please provide specificity
regarding Mr. Fahlberg`s plans to do personal selling in
conjunction
with mailing and telephone surveys.  How will he obtain a list(s)
of
potential contacts?  Where will he do the "personal selling"?
Also,
please explain your statement that "[H]e will gauge interest and
opportunity . . . ."
8. Please disclose the impact on the company`s operations should
it
not be able to fund the activities identified in the company`s
plan
of operation.  Will operations cease?  If so, disclose
management`s
intention for New Age Translation, Inc.  Your discussion should
include disclosure of how the company intends to manage its
reporting
obligations under the federal securities laws in the event the
company`s registration statement is declared effective.  Will the
company have the funds required to file current, quarterly, and
annual reports?  If operations cease due to a dire lack of
financing,
does the company anticipate commencing negotiations with potential
acquisition candidates?

Liquidity and Capital Resources, page 18
9. Identify the persons or class of persons to whom the private
placement was sold and $81,400 was raised.  Provide the date of
this
transaction.

Conflicts of Interest, page 20
10. Disclose the number hours per week Mr. Fahlberg devotes to the
company and the number of hours he devotes to the business of JAF
Consulting, Inc.
11. Describe the potential conflict of interest, if any, between
the
company and JAF Consulting.

Selling Shareholders, page 26
12. Please explain in more detail the reference to "all purchasers
have a preexisting relationship with us."

John A. Fahlberg
New Age Translation, Inc.
November 2, 2005
Page 4.
13. Please explain your statement that ". . . each had an
established
relationship with Mr. Fahlberg."
14. We note that some of these investors were also investors in
LDG,
Inc.  Explain how these investors were contacted with regard to
this
company and LDG.  We may have further comment.

Financial Statements
15. Please remove the interim statements of operations for the
three
months ended May 31, 2005 and 2004.  Registration statements
require
interim financial statements for the year-to-date periods only, in
this case, the six-months ended May 31, 2005 and 2004.
16. 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.

Exhibits

17. Please reconcile the differing names of your company as they
appear in the registration statement and exhibits.  Exhibit 3.1
states the name of the corporation as "New Age Education Holdings
Inc." while the registration statement shows the name to be "New
Age
Translation, Inc."  Please reconcile as appropriate.

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.

John A. Fahlberg
New Age Translation, Inc.
November 2, 2005
Page 5.

    	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.

      John A. Fahlberg
      New Age Translation, Inc.
      November 2, 2005
      Page 6.

       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

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

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