Mail Stop 04-06

      March 10, 2005

Mr. Andrew J. Kandalepas
Chairman & Chief Executive Officer
Dauphin Technology, Inc.
800 E. Northwest Highway, Suite 706
Palatine, Illinois  60067

Re:   	Dauphin Technology, Inc.
      Form 8-K filed March 8, 2005
      File No. 033-21537-D

Dear Mr. Kandalepas:

      We have reviewed your filing 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 comments are inapplicable or a revision
is
unnecessary. Please be as detailed as necessary in your
explanation.
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.

1. We note you have engaged the accounting firm of Tanner LC.  We
also note that Tanner LC is not registered 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 Tanner LC which should
include
an Exhibit 16 letter.


General

	 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 comment, 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.

      Please file your supplemental response and amendment via
EDGAR
in response to these comments within 10 days of the date of this
letter.  Please note that if you require longer than 10 days to
respond, you should contact the staff immediately to request
additional time.  Any questions regarding the above should be
directed to me at (202) 942-2894, or in my absence, to Robert
Benton
at (202) 942-1811.

Sincerely,



Christine Davis
      Staff Accountant

??

??

??

??

Dauphin Technology, Inc.
March 10, 2005
Page 2