December 16, 2005

Sent By Facsimile to 707-964-0351 and US Mail
Mr. Paul Katzeff
Thanksgiving Coffee Company, Inc.
19100 South Harbor Drive
Fort Bragg, CA 95437


	Re:	Thanksgiving Coffee Compay, Inc.
		Form 10-KSB for Fiscal Year Ended December 31, 2004
Filed March 23, 2005
		File No. 33-96070-LA


Dear Mr. Katzeff:

      We have reviewed your filing and have the following
comments. We
have limited our review of your filing to those issues we have
addressed
in our 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 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
us at
the telephone numbers listed at the end of this letter.

Form 10-KSB for the Fiscal Year Ended December 31, 2004

Report of Independent Accountants

1. We note that the auditors` report opining on your financial
statements
does not state the audit was conducted in accordance with
standards of the
Public Company Accounting Oversight Board.  Please include
financial
statements that are audited in accordance with the Public Company
Accounting Oversight Board.  See Interpretive Release 33-8422
Guidance
Regarding the Public Company Accounting Oversight Board`s Auditing
and
Related Professional Practice Standard No. 1 at
(http://www.sec.gov/rules/interp/33-8422.htmCommission).

Closing Comments

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us with
a response.  Please furnish a cover letter with your amendment
that keys
your responses to our comments and provides any requested
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.

	We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filing to be certain that the filing
includes all
information required under the Securities Exchange Act of 1934 and
that
they have provided all information investors require for an
informed
investment 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 the filing;

* 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.

      You may contact Gabrielle Malits, Staff Accountant, at (202)
551-
3702 if you have questions regarding comments on the financial
statements
and related matters.  Please contact me at (202) 551-3683 with any
other
questions.

								Sincerely,


								Jill Davis
								Branch Chief

??

??

??

??

Mr. Paul Katzeff
Thanksgiving Coffee Company, Inc.
December 16, 2005
page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, NE
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010