Michael A. Littman
                                 Attorney at Law
                                7609 Ralston Road
                                Arvada, CO 80002
                                 (303) 422-8127
                               Fax (303) 431-1567



                                 August 1, 2007



Securities and Exchange Commission
Attn:    Beverly A. Singleton
100 F Street, N.E.
Washington, DC 20549

Re:      The Saint James Company
         Item 4.01 Form 8-K, filed July 27, 2007
         File No. 0-13738

Dear Ms. Singleton,

         We have filed the  Amendment  to the Form 8-K,  filed on July 27,  2007
responsive to your comments dated July 31, 2007.

Item 4.01 Changes in Registrant's Certifying Accountants

1.  Please  amend the Item 4.01 Form 8-K in its  entirety  to also  provide  the
required Exhibit 16 letter form the former auditors,  Stonefield Josephson, Inc.
The letter  should be  addressed to us and  indicate  whether or not  Stonefield
Josephson,  Inc.  agrees with your  disclosures  contained in the Item 4.01 Form
8-K. Please refer to the  requirements of Item 304(a)(3) of Regulations  S-B. We
note that the Exhibit 16.1 letter,  as currently  filed,  represents  the former
auditors' letter of confirmation to you that the client-auditor relationship has
ceased.  In addition,  we noted that the Exhibit 23.2 letter, as currently filed
represents  the  letter  form the new  auditors,  Larry  O'Donnell,  CPA,  P.C.,
indicating they agree with your  disclosures.  It appears form the Item 4.01 8-K
disclosures that you had intended to file additional  correspondence  as Exhibit
23.1;  however,  such Exhibit was not filed with the Item 4.01 Form 8-K.  Please
include this Exhibit in the amended Item 4.01 Form 8-K, if appropriate,  and, if
such correspondence represents the former auditors' letter as to their agreement
or  disagreement  with your  disclosures,  please  file this  correspondence  as
Exhibit 16 rather than Exhibit 23.

         We have corrected the document for your comments.

If you have any questions or comments, please do not hesitate to contact us.

                                                     Sincerely,

                                                     /s/Michael A. Littman
                                                     Michael A. Littman


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