Room 4561

      February 7, 2006

Mr. David Loflin
President and Acting Chief Financial Officer
Diamond I, Inc.
16453 South Fulwar Skipwith Road
Baton Rouge, Louisiana 70810

      Re:	Diamond I, Inc.
		Form 8-K
      Filed February 3, 2006
      File No. 033-19961

Dear Mr. Loflin,

      We have reviewed the above referenced 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 comments are inapplicable
or
a revision is unnecessary.  Please be as detailed as necessary in
your explanation.  In our comments, we 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 8-K filed on February 3, 2006

Item 4.02.  Non-Reliance on Previously Issued Financial Statements
or
a Related Audit Report or Completed Interim Review
1. Please amend your report to include a brief description of the
facts underlying the conclusion to the extent known to you at the
time of the filing pursuant to Item 4.02(a) (2) of Form 8-K.



Form 10-QSB/A for the Fiscal Quarter Ended June 30, 2005
2. We note your disclosure from your June 30, 2005 amended Form
10-
QSB, "This amended Quarterly Report on Form 10-QSB for the period
ended June 30, 2005, is being filed inasmuch as the original
report
was filed without review by Registrant`s independent auditor and
the
result of identified errors within the previously reported
financial
statements of Registrant."  Explain why the original interim
report
was filed without review of your independent auditor which is
required pursuant to Regulation S-B, Item 310(b).

Item 3.  Controls and Procedures

3. We note your Chief Executive Officer and Acting Chief Financial
Officer concluded your disclosure controls and procedures are "not
effective in timely alerting him and other members of management
to
material information about our company required to be disclosed by
us
in our periodic reports that we file or submit under the
Securities
Exchange Act of 1934."  Revise to clarify, if true, that your
officers concluded that your disclosure controls and procedures
are
also not effectively designed to ensure information required to be
disclosed by the Company in reports it files or submits under the
Exchange Act is recorded, processed, summarized and reported
within
the time periods specified in Securities and Exchange Commission
rules and forms.  We refer you to Exchange Act Rule 13a-15(b) (2)
(e).
4. We note your disclosure that you "detected a material weakness
in
the assimilation of financial information into the preparation
process associated with our periodic reports filed under the
Securities Exchange Act of 1934, in that we were late in filing
this
report, there were material adjustments required by our auditors".
Revise to clarify whether you filing your interim report without
independent auditor review caused or impacted this material
weakness.
5. We note your disclosure, "We believe necessary corrections to
these processes have been implemented, effective for the third
quarter of 2005."  Revise to disclose the specific steps that you
have taken to remediate the material weakness.

      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 submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
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 any amendment and your response 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 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.

      You may contact Chris White, Staff Accountant, at (202) 551-
3461 or me at (202) 551-3488 if you have any questions regarding
our
comments.


								Sincerely,



								Stephen Krikorian
								Accounting Branch Chief
Mr. David Loflin
Diamond I, Inc.
February 7, 2006
Page 1