CORRESP 1 filename1.txt GALES INDUSTRIES INCORPORATED 1479 North Clinton Avenue Bay Shore, NY 11706 August 3, 2006 Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Re: Gales Industries Incorporated (the "Company"); Form SB-2 Registration Statement of the Company, File No.: 333-131709 (the "Registration Statement") Dear Sirs: Gales Industries Incorporated, a Delaware corporation, respectfully requests that the Commission issue its order declaring the above-referenced Registration Statement on Form SB-2 to be effective in accordance with Section 8(a) of the Securities Act of 1933, as amended, at 4:00 PM (eastern standard time) on Friday, August 4, 2006. The Company acknowledges and confirms to the Commission that: o should the Commission or the Staff, acting pursuant to delegated authority, declare the SB-2 effective, it does not foreclose the Commission from taking any action with respect to the SB-2; o the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the SB-2 effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosures in the SB-2; and o the Company may not assert staff comments 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, GALES INDUSTRIES INCORPORATED By: /s/ Michael A. Gales ------------------------------------ Michael A. Gales, Executive Chairman