PARSONS LAW FIRM
ATTORNEYS AT LAW
SUITE 2070
10900 NE 4th Street
BELLEVUE, WASHINGTON 98004
(425) 451-8036 FAX (425) 451-8568
James B. Parsons* www.parsonslaw.biz * Also admitted in Oregon and
jparsons@parsonslaw.biz &nb sp; the Northern Mariana Islands
VIA OVERNIGHT MAIL AND FILED ON EDGAR CORRESPONDENCE
April 20, 2006
Ms. Goldie B. Walker
Mr. John D. Reynolds
United States Securities and Exchange Commission
Division of Corporation Finances
Mail Stop 3561
Washington, D.C. 20549
Re: Deltron, Inc.
Registration No. 333-130197
SB-2/A filed April 20, 2006
Dear Ms. Walker and Mr. Reynolds:
In response to the comments made in previous correspondence from the Commission, the Company has requested I respond as follows:
General
The filing has been amended to reflect that Deltron, through its wholly owned Costa Rican corporation, purchased real estate in Costa Rica. In addition, the filing has been amended to indicate the expenditure of funds to develop the property purchased. Finally, updated financials have been included for this filing.
Please contact this office with any further comments or questions. We are filing the redlined version and this letter on EDGAR correspondence, as well as sending you three (3) copies of the redlined and accepted versions via overnight mail. I would appreciate if you would send any further responses directly to me electronically or via facsimile, so I may assist Deltron in a prompt response. If the SEC has no further comments, we expect to file a request for acceleration of the effective date.
Thank you in advance for your courtesies.
Very truly yours,
PARSONS LAW FIRM
/s/ James B. Parsons
James B. Parsons
cc: Client
