November 2, 2004
Zip+4 Code:  20549-0305

Via Fax & U.S. Mail

Mr. Mendel Klein
Chief Financial Officer
Laser Master International, Inc.
1000 First Street
Harrison, New Jersey 07029

	Re:	Form 8-K filed October 29, 2004
File No.: 2-76262-NY

Dear Mr. Klein:

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 comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  In some of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  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.

Exhibit 16

1. You state that for the two most recent fiscal years and through the
date of the resignation, the Company did not, to the knowledge of
present management, have any disagreements with Goldstein and Morris.
Please explain to us what procedures present management performed to
enable them to conclude that there were no disagreements with the
former accountant.

2. Please file a letter from your former accountant, indicating
whether or not they agree with your disclosures in the Form 8-K.



Engagement of new accountant

3. When you engage a new accountant, please report the engagement in a
new Form 8-K and comply with the requirements of Regulation S-K Item
304 (a)(2).  In making any disclosures about consultations with your
new accountants, please ensure you disclose any consultations up
through the date of engagement.

Other

4. We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to be
certain that they have provided all information investors require.
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 comments, 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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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 five business days of the date of
this letter.  Please note that if you require longer than five
business days to respond, you should contact the staff immediately to
request additional time.








You may contact Effie Simpson at (202) 942-2838 or Bob Benton, Senior
Accountant, at (202) 942-1811 if you have any questions.

								Sincerely,


								Effie Simpson
								Staff Accountant
Mr. Mendel Klein
Laser Master International, Inc.
November 2, 2004
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