Zone 4 Play, Inc.
                                 103 Foulk Road
                              Wilmington, DE 19803

                                                              February 7, 2005

VIA FACSIMILE AND EDGAR
United States Securities
 and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention:  Michael McTiernan, Esq.

         Re:      Zone 4 Play, Inc.
                  Registration Statement on Form SB-2
                  File No. 333-120174

Ladies and Gentlemen:

      Pursuant to Rule 461 of the General Rules and Regulations under the
Securities Act of 1933, as amended (the "Act"), Zone 4 Play, Inc. (the
"Company") respectfully requests that the effective date of the Registration
Statement referred to above be accelerated so that it will become effective at
4:00 pm, Eastern Time, on Wednesday, February 9, 2005, or as soon thereafter as
possible.

      We hereby acknowledge the following:

      o     that should the Commission or the staff, acting pursuant to
            delegated authority, declare the filing effective, it does not
            foreclose the Commission from taking any action with respect to the
            filing;

      o     the action of the Commission or the staff, acting pursuant to
            delegated authority, in declaring the filing effective, does not
            relieve the Company from its full responsibility for the adequacy
            and accuracy of the disclosure in the filing; and

      o     the Company may not assert this action as a defense in any
            proceeding initiated by the Commission or any person under the
            federal securities laws of the United States

                                        Zone 4 Play, Inc.

                                        By: /s/ Uri Levy
                                           -------------------------------------
                                           Name:  Uri Levy
                                           Title: Chief Financial Officer