EXHIBIT 16-1


                   [Letterhead of DIXON, ODOM & CO., L.L.P.]
                          Certified Public Accountants





July 21, 1997


Securities and Exchange Commission
Washington, DC 20549

Ladies and Gentlemen:

We have read the first paragraph included under Item 4 of the Form 8-K of Market
America, Inc. dated July 17, 1997 and agree with the statements contained
therein.

Very truly yours,

/s/ Dixon, Odom & Co., L.L.P.
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Dixon, Odom & Co., L.L.P.