


Mail Stop 4561

September 22, 2005

VIA U.S. MAIL AND FAX (212)504-8120

Albert H. Pleus
Chairman of the Board and Chief Executive Officer
a21, Inc.
7660 Centurion Parkway
Jacksonville, Florida 32256

Re: a21, Inc..
	Item 4.02 Form 8-K
	File no. 000-51285
	Filed September 19, 2005


Dear Mr. Pleus:

      We have reviewed your filing and have the following
comments.
In some of our comments, we may 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 number
listed
at the end of this letter.


Form 8-K
1. Please tell us if your certifying officers have reconsidered
the
effect on the adequacy of your disclosure controls and procedures
as
of the end of the period covered by your Forms 10-Q for the
periods
ended March 31, 2004, June 30, 2004 and September 30, 2004 and
March
31, 2005 as well as your Form 10-K for the year ended December 31,
2005 in light of the material error you have disclosed.
Additionally, tell us what effect the error had on your current
evaluation of disclosure controls and procedures as of your fiscal
year end December 31, 2005.

   We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.



Please provide the supplemental information requested above within
5
business days from the date of this letter.  The supplemental
information should be filed as correspondence on EDGAR.

      Any questions regarding the above should be directed to me
at
(202) 551-3438.

							Sincerely,


							Robert F. Telewicz, Jr.
							Staff Accountant
Albert H. Pleus
a21, Inc
September 22, 2005
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