May 25, 2005
Room 4561

Sterling E. Phillips
Chairman of the Board and Chief Executive Officer
Analex Corporation
5904 Richmond Highway
Suite 300
Alexandria, VA 22303

Re:	Analex Corporation
	Form S-3 filed April 29, 2005
	Registration no. 333-124447

	Form 10-K filed March 28, 2005
	File no. 1-31613

Dear Mr. Phillips:

      We have limited our review of the forgoing filings to
signatures required concerning the registration statement and the
controls and procedures disclosure in your Form 10-K.  Based on
this
limited review, we 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 supplemental information so we
may
better understand your disclosure.  After reviewing this
information,
we may or may not 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form S-3
Signature Page

1. The person discharging the functions of comptroller or chief
accounting officer should sign the registration statement, or if a
person serving in that capacity is signing the filing in another
capacity, they should be also designated as comptroller or chief
accounting officer.
Form 10-K
Item 9A. Controls and Procedures, pages 30-31

2. Management`s effectiveness conclusion, expressed in the second
paragraph, concerns "timely alerting them to material information
relating to the Company required to be included in the company`s
periodic SEC filings".  As such, the scope of the conclusion is
more
narrow than the determination required of management, which should
conform to the definition of "disclosure controls and procedures"
contained in Rule 13(a)-15(e).  In your response letter, please
tell
us supplementally whether the conclusion as to effectiveness
pertained to "disclosure controls and procedures" as defined in
Rule
13(a)-15(e).  Also, confirm that you will consider this comment in
the preparation of future periodic reports.

3. In the final paragraph of Item 9A, you state that there were no
"significant" changes to your internal controls over financial
reporting during the applicable quarter.  Please refer to Item
308(c)
and note that you should disclose any changes in internal controls
over financial reporting that have materially affected, or are
reasonably likely to materially affect, Analex`s internal controls
over financial reporting.  In your response letter, please advise
us
in this regard with respect to the fourth quarter.  Also, confirm
that you will consider this comment in the preparation of future
periodic reports.

Form S-3
Incorporation by Reference, page 24

4. Please revise this section to specifically incorporate reports
filed under Section 13(a) of the Exchange Act that were made since
the filing of this registration statement.

General

      As appropriate, please amend your registration statement in
response to these comments.  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 supplemental 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 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.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in 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.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rule 461 regarding requesting
acceleration of a registration statement.  Please allow adequate
time
after the filing of any amendment for further review before
submitting a request for acceleration.  Please provide this
request
at least two business days in advance of the requested effective
date.

	Please direct any questions to Hugh Fuller at (202)551-3853.

								Sincerely,



								Mark P. Shuman
								Branch Chief - Legal

CC:	Jane K. P. Tam
	Holland & Knight LLP
	2099 Pennsylvania Avenue, NW
	Washington, DC 20006
	FAX no. (202) 955-5564