October 21, 2004

Via US Mail

Mr. Terrence Barber, Chief Executive Officer
The Ricex Company
1241 Hawk`s Flight Court
El Dorado Hills, California 95762

RE:  Form 8-K filed on October 5, 2004
        The Ricex Company - File No. 0-24285

Dear Mr. Barber:

             The staff has reviewed the above-referenced filing for
compliance with the requirements of Form 8-K and has the following
comments in that regard.  Feel free to contact us at the number
listed at the end of this letter.  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.

Reportable events

Refer to the paragraphs of the Form 8-K where you identify the
accounting disagreement and please tell us in a supplemental letter:

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) how the disagreement was resolved,
5) how and by whom any amounts were determined, and
6) whether or not you restated (or intend to restate) any prior
period for any adjustment, and if not, why.

Please also note the requirements of Item 304(b) of Regulation S-K.
If there were any material transactions or events similar to those
involved in the disagreement that you accounted for or disclosed
differently than your prior accountant would have concluded was
required, you should provide all of the disclosures required by Item
304(b) of Regulation S-K.

Provide us with any letters or written communication to and from the
former accountants regarding the disagreement and their resolution to
management or the Audit Committee.

To the extent that you make changes to the Form 8-K to comply with
our comments, please obtain and file an updated Exhibit 16 letter
from the former accountants stating whether the accountant agrees
with the statements made in your revised Form 8-K.

General

Please file your supplemental response and amendment (if appropriate)
via EDGAR in response to these comments within 5 business days of the
date of this letter.  Please note that if you require longer than 5
business days to respond, you should contact the staff immediately to
request additional time.  Direct any questions regarding the above to
John A. Weitzel, Staff Accountant at (202) 942-1807.


								Sincerely,


								John A. Weitzel
								Staff Accountant





Mr. Terrence Barber
The Ricex Company
October 21, 2004
Page 2




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

       DIVISION OF
CORPORATION FINANCE