Mail Stop 7010 September 27, 2005 via U.S. mail and facsimile Mr. John T. Sawyer President and Chief Executive Officer, Penhall International Corp. 1801 Penhall Way Anaheim, CA 92803 	RE:	Form 10-K/A for the fiscal year ended June 30, 2004 		Form 10-Q for the period ended March 31, 2005 			File No. 333-64745 Dear Mr. Sawyer: We have completed our review of your Form 10-K and related filings and have no further comments at this time. If you have any further questions regarding our review of your filings, please direct them to Marie Trimeloni, Staff Accountant, at (202) 551-3734 or, in her absence, to Jeanne Baker, Assistant Chief Accountant, at (202) 551-3691. 							Sincerely, 							Rufus Decker 							Accounting Branch Chief ?? ?? ?? ?? Mr. J. Gordon Beittenmiller March 25, 2005 Page 2 of 1 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-0510 DIVISION OF CORPORATION FINANCE