Mail Stop 3561

							November 25, 2005

Bernard L. Brodkorb
President
ISA International, Inc.
2560 Rice Street
St. Paul, MN  55113

RE:	ISA International, Inc.
	Item 4.01 Form 8-K filed October 19, 2005
	Item 4.01 Form 8-K filed October 28, 2005
	Item 4.01 Form 8-K filed November 23, 2005
            File No. 1-16423

Dear Mr. Brodkorb:

          We have reviewed your filings 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.

          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 contact us at the telephone numbers
listed
at the end of this letter.
1. In a letter dated October 19, 2005 we requested you to revise
your
Item 4.01 Form 8-K filed October 19, 2005 to disclose information
about any disagreements with your former accountants.  We do not
see
where either the October 28, 2005 or November 23, 2005 made the
revisions we requested.  We note the statement in the third
paragraph
of your November 23, 2005 filing that you believe you are in
compliance with reporting requirements; however, it does not
appear
to us that this is the case.  Please either make the revisions we
requested or tell us why no further revision is necessary.
2. In our October 19, 2005 letter we requested you to make certain
representations; however, we do not see where you provided them.
We
have repeated the information we requested in this letter.  Please
either provide the representations or tell us why you cannot
provide
them.

Bernard L. Brodkorb
ISA International, Inc.
November 23, 2005
Page 2



      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing 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
disclosures 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 this action 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 connection with our review of
your
filing or in response to our comments on your filing.

	As appropriate, please amend your filing and respond to these
comments within five business days or tell us when you will
respond.
Please furnish a cover letter with your amendment that keys your
responses to our comments and provides the representations
requested
above.  Please file the cover letter as correspondence on our
EDGAR
system.   Any questions regarding the above should be directed to
Robert Burnett, Staff Accountant, at (202) 551-3330, or in his
absence, to me at (202) 551-3841.

							Sincerely,



							Michael Moran
						            Branch Chief


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