April 12, 2005


Mail Stop 0409

David C. Warren
Chief Executive Officer and Director
eMerge Interactive, Inc.
10305 102nd Terrace
Sebastian, FL  32958

Re:	eMerge Interactive, Inc.
	Form 10-K for the year ended December 31, 2004
      File No. 000-29037

Dear Mr. Warren:

      We have reviewed your filing and have the following comment.
We have limited our review to only the issues addressed below and
will make no further review of your documents.  As such, all
persons
who are responsible for the adequacy and accuracy of the
disclosure
are urged to be certain that they have included all information
required pursuant to the Securities Exchange Act of 1934.

      Where indicated, we think you should revise your document in
response to this comment in future filings.  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.

	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 comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the year ended December 31, 2004

Consolidated Statements of Operations, page F-3

1. In future filings, separately state net sales of tangible
products, income from rentals, revenues from services and other
revenues.  The costs related to these revenues should also be
presented on a disaggregated basis as applicable.  Refer to Rule
5-
03(b) of Regulation S-X and SAB 101.

      As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your proposed revisions that
keys
your response to our comment.  Detailed cover letters greatly
facilitate our review.  Please file your cover letter on EDGAR.
Please understand that we may have additional comments after
reviewing your response to our comment.

	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.

	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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.


      You may contact Kristi Beshears, Staff Accountant, at (202)
824-5346 or the undersigned at (202) 942-1964 if you have
questions.



						Sincerely,



Linda van Doorn
Senior Assistant Chief Accountant

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eMerge Interactive, Inc.
April 12, 2005
Page 1