Mail Stop 04-06

      March 3, 2005

Mr. William C. Wimer
Vice President of Operations and
  Chief Financial Officer
Unitronix Corporation
2320 East North Street, SuiteGG
Greenville, SC 29607
(978) 887-5608

Re:   	Unitronix Corporation
      Form 8-K filed February 22, 2005
      File No. 000-17080

Dear Mr. Wimer:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your documents 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.

Form 8-K, filed February 22, 2005
1. Item 304(a)(1)(ii) of Regulation S-K requires a statement
regarding whether the accountant`s report on the financial
statements
for either of the past two years contained an adverse opinion or a
disclaimer of opinion or was qualified or modified as to
uncertainty,
audit scope or accounting principles; and a description of the
nature
of each such adverse opinion, disclaimer of opinion, modification
or
qualification.  This would include disclosure of uncertainty
regarding the ability to continue as a going concern in the
accountant`s report.  Revise your disclosure to include a
discussion
of the modification contained in the audit report dated September
20,
2004, included in your Form 10-K filed on September 28, 2004 for a
going concern uncertainty.  Please include your exhibit 16 letter
from your former accountant in the amendment.

Forms 10-Q for the quarterly periods ended March 31, 2004 and
September 30, 2004

Item 4. Controls and Procedures

We monitored your Forms 10-K and 10-Q solely related to the
matters
below.
2. We note your statement in Forms 10-Q that your chief executive
officer and your chief financial officer "have concluded that as
of
the Evaluation Date our disclosure controls and procedures were
adequate and designed to ensure that material information relating
to
us and our consolidated subsidiaries would be made known to them
by
others within those entities."  It does not appear that your
certifying officers have reached a conclusion that your disclosure
controls and procedures are effective.  Please revise your filings
to
address your officers` conclusions regarding the effectiveness of
your disclosure controls and procedures.

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.


      Regarding your Form 8-K, please file your supplemental
response
and amendment via EDGAR in response to the 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 Form 8-K
should
be directed to the undersigned at (202) 942-2806, or in my
absence,
to Robert Benton at (202) 942-1811.


Sincerely,


David W. Edgar
      Staff Accountant
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Unitronix Corporation
March 3, 2005
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