Mail Stop 0510

      May 3, 2005

By U.S. Mail and facsimile to (718) 472-5316

Mr. Shay Goldstein
c/o Mr. David Lubin
David Lubin & Associates
92 Washington Avenue
Cedarhurst, New York 11516

Re:	Safetek International, Inc.
	Form 10-KSB for the year ended December 31, 2004
      File No. 33-22175


Dear Mr. Goldstein:

      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.

FORM 10-KSB FOR THE YEAR ENDED DECEMBER 31, 2004

Independent Auditors` Reports

1. We note your filing includes the audit opinion of Tschopp,
Whitcomb & Orr, P.A., dated December 30, 2003, covering the years
ended December 31, 2002 and 2001.  We assume that you included
this
opinion in error and that you intended to include their opinion
covering the year ended December 31, 2003.  Please confirm our
assumption.  Please amend your filing to include an independent
auditors` report that covers the year ended December 31, 2003.
You
should also apply this comment to your December 31, 2003 10-KSB
and
amend that filing, since we notice that it does not contain an
independent auditors` report covering the year ended December 31,
2003 either.  Refer to Item 310(a) of Regulation S-B and Rule 2-02
of
Regulation S-X.

Future Acquisitions

2. We read that management is looking for a merger or acquisition
candidate.  We remind you of our proposed Rule 33-8407, which
would
require a public shell company, when reporting an event that
causes
it to cease being a shell company, to file a Form 8-K containing
the
same type of information that it would be required to file to
register a class of securities under the Exchange Act.  We advise
you
to follow the guidance in the proposed release or final rule, when
adopted.  If you have any questions in this regard, at the time an
acquisition or merger candidate is identified, please feel free to
contact the Staff.


*	*	*
Closing Comments


		Please respond to these comments within 10 business
days,
or tell us when you will provide us with a response.  Please
provide
us with a supplemental response letter that keys your responses to
our comments and provides any requested supplemental information.
Detailed letters greatly facilitate our review.  Please file your
supplemental response on EDGAR as a correspondence file.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

      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
for
an informed 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 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 their filings;
* 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.

      If you have any questions regarding these comments, please
direct them to Jennifer Thompson, Staff Accountant, at (202) 824-
5259
or, in her absence, to Nathan Cheney, Assistant Chief Accountant,
at
(202) 942-1804 or the undersigned at (202) 824-5373.


Sincerely,




John Cash
Accounting Branch Chief


Mr. Shay Goldstein
May 3, 2005
Page 1 of 3



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE