Mail Stop 4561

June 3, 2005

Via facsimile to (954) 660-6561 and U.S. Mail

Mr. Gerard A. Herlihy
Chief Financial Officer
Splinex Technology Inc.
550 W. Cypress Creek Road, Suite 410
Fort Lauderdale, FL  33309

Re:   	Splinex Technology Inc.
      Item 4.01 Form 8-K
      Filed February 2, 2005
      File No. 333-116817

Dear Mr. Herlihy:

      We have reviewed your correspondence dated April 12, 2005
and
have the following comments.  We may ask you to provide us with
supplemental information so we may better understand your
disclosure.
Please be as detailed as necessary in your explanation.  After
reviewing this information, we may raise additional comments.
After
reviewing this information, we may or may not raise additional
comments.

      We welcome any questions you may have about our comments or
any
other aspect of our review.  Feel free to call us at the telephone
numbers listed at the end of this letter.

Prior comment 1
1. We note your statement that the material weaknesses were first
orally communicated by the Company`s former auditor on February 1,
2005.  Please explain why, in the last sentence of the second
paragraph of your response, you state that the  weaknesses were
"described in a workpaper delivered by the Company`s former
auditor
to the Company in January 2005."
2. Tell us supplementally, specifically when the material
weaknesses
were identified, when they are believed to have begun, by whom
they
were identified and when they were first communicated.

Prior comment 3

3. We understand from your correspondence of April 12, 2005, that
the
only written communication received from your former auditor
regarding the material internal control weaknesses was a copy of
an
audit workpaper.  As previously requested, please provide a copy
of
this document.

Prior comment 4

4. We have reviewed your response and note that you disclose in
Item
3 that "management recognized" that controls and procedures can
provide only reasonable assurance of achieving the desired control
objectives.  This recognition is not the equivalent of designing
disclosure controls and procedures to provide reasonable assurance
of
achieving their objectives.  Please confirm to us that in future
filings you will revise to state clearly, if true, that your
disclosure controls and procedures are designed to provide
reasonable
assurance of achieving their objectives.  In the alternative, all
references to the level of assurance of your disclosure controls
and
procedures may be removed from your disclosures.

Prior comment 5
5. We note that you made changes to disclosure controls and
procedures prior to the communication that there were material
weaknesses.  Tell us how you knew about the material weaknesses
before the former accountant advised you of them. Tell us exactly
when the company implemented changes to disclosure controls and
procedures.  Describe the changes in reasonable detail and why
those
changes support the basis for your officers` conclusions that the
company`s disclosure controls and procedures were nonetheless
effective as of the end of the period covered by the report.

       Please respond to these comments within five business days
or
tell us when you will provide us with a response.  Please furnish
a
cover letter that keys your responses to our comments and provides
any requested supplemental information.  Detailed cover letters
greatly facilitate our review.  Please understand that we may have
additional comments after reviewing your amendment and responses
to
our comments.

      Any questions regarding the above should be directed to me
at
(202) 551-3443, or in my absence, to Robert Benton at (202) 551-
3804.

Sincerely,


Tamara Tangen, CPA
      Staff Accountant
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Gerard A. Herlihy
Splinex Technology Inc.
June 3, 2005
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