February 23, 2005

Mail Stop 0511

Mr. Ivan Zweig, CEO
Mailkey Corporation
17194 Preston Rd., Suite 102 PMB 341
Dallas, TX 75248


Re: Form 8-K filed 2/04/2005
      File No. 0-29331

Dear Mr. Zweig:

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.
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 any other aspect of
our
review.  Feel free to call the applicable staff person at the
telephone number listed at the end of this letter.

Item 304(a)(1)(iv)(A) of Regulation S-B requires you to disclose
whether during the registrant`s two most recent fiscal years and
any
subsequent interim period through the date of resignation,
declination or dismissal there were any disagreements, resolved or
not, with the former accountant on any matter of accounting
principles or practices, financial statement disclosure, or
auditing
scope or procedure, which disagreement(s), if not resolved to the
satisfaction of the former accountant, would have caused it to
make
reference to the subject matter of the disagreement(s) in
connection
with its reports.  Please revise to clarify that the period
covered
includes the period through the dismissal date (July 6, 2004 for
Spicer, Jeffries & Co.).
In a similar manner, revise to address Item 304(a) (1) (iv) (A) as
it
applies to LJ Soldinger Associates up to the dismissal date
(January
31, 2005).



Mailkey Corporation
File No. 0-29331


Please note that the amended Form 8-K should be appropriately
signed
as required by Form 8-K.

You should file your supplemental response and amendment via EDGAR
in
response to these comments within 5 business days after the date
of
this letter.  Please contact the staff immediately if you require
longer than 5 business days to respond.

Please direct any questions regarding this letter to the
undersigned
at 202.942.1856.


						Sincerely,


						Donald G. Wiland
						Staff Accountant
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0306

         DIVISION OF
CORPORATION FINANCE