Mail Stop 6010

      August 4, 2005

Via Facsimile and U.S. Mail

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

Re:	Univec, Inc.
	Item 4.01 Form 8-K
      Filed August 1, 2005
	File No. 0-22413

Dear Mr. Dalton:

      We have reviewed your filing and have the following comment.
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 July 28, 2005

Item 4.01 - Change in Registrant`s Certifying Accountant

1. We note you have engaged the accounting firm of Abrams, Foster,
Nole & Williams, P.A. to audit your year ended December 31, 2004
financial statements.  We also note that the firm of Abrams,
Foster,
Nole & Williams, P.A. has not applied for registration with the
Public Company Accounting Oversight Board (PCAOB).  Section 102 of
the Sarbanes-Oxley Act of 2002 makes it unlawful after October 22,
2003 for any person that is not a registered public accounting
firm
(i.e. registered with the PCAOB) to prepare or issue, or to
participate in the preparation or issuance of, any audit report
(or
review report) with respect to any issuer.  You must engage a new
accountant that is a publicly registered accounting firm to
perform
review or audit work for the company.  Please file a new Item 4
Form
8-K after you have engaged new accountants that are registered
with
the PCAOB.  Provide all of the disclosures required by Item 304 of
Regulation S-K regarding the period of engagement of Abrams,
Foster,
Nole & Williams, P.A. which should include an Exhibit 16 letter
from
them.


*    *    *    *























       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.
August 4, 2005
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