Mail Stop 6010

      June 24, 2005

Via Facsimile and U.S. Mail

Mr. David Dalton
Chief Executive Officer
Univec, Inc.
4810 Seton Drive
Baltimore, MD   21215

Re:	Univec, Inc.
	Items 4.01 and 4.02 Form 8-K
      Filed June 13, 2005
	File No. 0-22413

Dear Mr. Dalton:

      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 more
information so we may better understand your disclosure.  After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.









Form 8-K dated June 9, 2005

Item 4.01 - Change in Registrant`s Certifying Accountant

1. Disclose whether the former auditor`s report on your financial
statements for either of the past two years contained an adverse
opinion, a disclaimer of opinion, or was qualified or modified as
to
uncertainty, audit scope or accounting principles and, if so,
describe the nature of each adverse opinion, disclaimer of
opinion,
modification or qualification. See Item 304(a)(1)(ii) of
Regulation
S-B.

2. Refer to the third paragraph of the Form 8-K where you identify
accounting disagreement.  For the disagreement, please tell us
supplementally:

1) what period the disagreement relates to,
2) the nature of the disagreement including the company`s position
and the former accountant`s position at the time of the
disagreement,
3) the amounts involved,
4) why the disagreement could not be resolved or how it was
resolved,
5) how and by whom any amounts were determined, and
6) whether or not you intend to restate any prior period for any
adjustment, and if not, why.

3. With respect to the disagreement with the former accountant,
revise the Form 8-K to provide all the information required by
Item
304(a)(1)(C)-(E) of Regulation S-B.

4. To the extent that you amend the Form 8-K to comply with our
comments, please obtain and file an updated Exhibit 16 letter from
the former accountant stating whether the accountant agrees with
your
Item 304 disclosures, or the extent to which the accountant does
not
agree.

Item 4.02 - Non-reliance on Previously Issued Financial Statements
or
a Related Audit Report or Completed Interim Report

5. Please amend the filing to state whether the audit committee,
or
the board of directors in the absence of an audit committee, or
authorized officer or officers, discussed with the independent
accountant the matters disclosed in the filing. Refer to Item
4.02(b)
of Form 8-K.

6. Item 4.02(c) of Form 8-K requires you to provide your
independent
accountant with a copy of the disclosure you are making in
response
to Item 4.02(b) and request that it furnish you with a letter
stating
whether it agrees with the statements you have made in response to
Item 4.02(b).  Amend your Form 8-K to file this letter as an
exhibit
no later than two business days after you receive it.

7. Please tell us whether you intend to file restated financial
statements. If so, tell us how, and when, you will file the
related
reports.

8. Please tell us if your certifying officers have considered the
effect of the error on the adequacy of your disclosure controls
and
procedures as of the end of the period covered by your Forms 10-K
for
the period ended December 31, 2003 and 10-Q for the quarters ended
March 31, 2004, June 30, 2004 and September 30, 2004.

9. Please file a new Item 4.01 Form 8-K as soon as you engage a
new
accountant.


*    *    *    *

























       As appropriate, please amend your filing and respond to
these
comments within five business days or tell us when you will
provide
us with a response.  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
provides any requested 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 filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* 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.

      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 our review of your filing or in
response to our comments on your filing.

	If you have any questions, please call David Burton at (202)
551-3626.

							Sincerely,


							David Burton
							Staff Accountant



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Mr. David Dalton
Univec, Inc.
June 24, 2005
Page 4