November 30,
2005


Mail Stop 3561

Via US Mail and Facsimile

Mr. Greg Smith
Chief Executive Officer and Chief Financial Officer
ERF Wireless, Inc.
2911 South Shore Blvd., Suite 100
League City, Texas 77573

Re:	ERF Wireless, Inc.
	Form 10-KSB for the year ended December 31, 2004
	Forms 10-QSB for the periods ended March 31, 2005, June 30,
2005
and
      September 30, 2005
	Commission file #: 000-27467

Dear Mr. Smith:

We have reviewed your October 31, 2005 response letter 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 comments are inapplicable
or a
revision is unnecessary.  We also ask you to provide us with
supplemental information so we may better understand your
disclosure.
Please be as detailed as necessary in your explanation.  We look
forward to working with you in these respects and welcome any
questions you may have about any aspects of our review.

* * * * * * * * * * * * * * * * * * * * * * *

Forms 10-QSB for the quarter ended March 31, 2005, June 30, 2005
and
September 30, 2005

1. We note from your disclosure in Item 3 that your chief
executive
officer and principal financial officer concluded that your
disclosure
controls and procedures were adequate.  Please confirm to us that
your
disclosure controls and procedures were effective as of the end of
the
last three quarters in 2005.  In future filings, please do not use
the
word adequate to address your disclosure controls and procedures,
but
instead conclude on the effectiveness of those controls and
procedures
as outlined in the guidance in Item 307 of Regulation S-K.

* * * * * * * * * * * * * * * * * * * * * * *

As appropriate, please respond to these comments via EDGAR within
10
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.

You may contact Claire Erlanger at 202-551-3301 or me at 202-551-
3813
if you have questions.

      Sincerely,


								Linda Cvrkel
								Branch Chief
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Mr. Greg Smith
ERF Wireless, Inc.
November 30, 2005
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