Mail Stop 4561

      							October 25, 2005

Terrence S. Cassidy
Principal Executive Officer and Principal Financial Officer
NWH, Inc.
156 West 56 Street
Suite 2001
New York, NY 10019

	Re:	NWH, Inc.
		Form 10-K for the Fiscal Year Ended October 31, 2004
      Form 10-Q for the Fiscal Quarter Ended January 31, 2005
      Form 10-Q for the Fiscal Quarter Ended April 30, 2005
      Form 10-Q for the Fiscal Quarter Ended July 31, 2005
      File No. 000-26598

Dear Mr. Cassidy:

		We have reviewed your response dated October 12, 2005
and
have the following comment.  Please note that we have limited our
review to the matters addressed in the comment below.  We may ask
you
to provide us with supplemental information so we may better
understand your disclosure.  Please be as detailed as necessary in
your explanation.  After reviewing this information, we may 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 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-Q for the Quarterly Period Ended April 30, 2005

Item 2.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

Use of Non-GAAP Financial Measures, page 22

1. Your response to prior comment number 1 indicates that your
CODM
recently changed the measure of ENS segment profit (loss) used to
evaluated the performance of ENS and decide how to allocate
resources.  Tell us when your CODM made this change.  That is,
clarify whether your CODM used your current or prior measure of
segment profit (loss) to assess the performance of ENS and to
decide
how to allocate resources for the year-ended October 31, 2004 and
subsequent quarters.  If your CODM has always used your current
measure, this change is a correction of an error since the
company`s
financial statements did not comply with SFAS 131 in previously
issued financial statements pursuant to APB Opinion No. 20,
paragraph
36.  Further, the current measure of segment performance as of
October 31, 2004 was $3,201,478 and the prior measure as disclosed
in
the footnotes was $1,617,014 which is a significant difference.
More
importantly, the disclosure fails to satisfy the requirements of
SFAS
131 to disclose the segment measured used which cannot be remedy
by
disclosure "outside" of the audited financial statements that are
prepared in accordance with GAAP.  If the change is deemed a
correction of an error, restate and amend previously filed
Exchange
Act reports including your October 31, 2004 Form 10-K and
subsequent
quarterly filings.

*****

      As appropriate, please amend your filing and respond to this
comment within 10 business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
amendment that keys your responses to our comment and provides any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing any amendment and your responses to our comment.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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.

	You may contact Christopher White, Staff Accountant, at (202)
551-3461 or me at (202) 551-3488 if you have any questions
regarding
our comment on the financial statements and related matters.


								Sincerely,


								Stephen Krikorian
								Accounting Branch Chief


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Terrence S. Cassidy
NWH, Inc.
October 25, 2005
page 1