ARKADOS GROUP, INC.
220 Old New Brunswick Road, Suite 202
Piscataway, NJ 08854
April 19, 2007
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attn: Robert Telewicz
Senior Staff Accountant
Yolanda Crittendon
Staff Accountant
Re: Arkados Group, Inc. (the “Company”)
Form 10-KSB for Fiscal Year Ended May 31, 2006
Form 10-QSB for Fiscal Quarter Ended August 31, 2006
Ladies and Gentlemen:
In connection with your consideration of our responses to the Staff’s comments during a telephone conference call on March 29, 2007, we acknowledge that:
| · | Arkados 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 |
| · | Arkados 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. |
Thank you for your attention.
Very truly yours,
/s/ Barbara Kane-Burke
Barbara Kane-Burke
Chief Financial Officer
