April 27, 2005



Mail Stop 04-09

VIA U.S. MAIL AND FAX 1-312-458-3058

Mr.  Shaun O`Brien
Chief Financial Officer
CIS Investments, Inc.
233 South Wacker Drive, Suite 2300
Chicago, IL 60606

RE:	JWH Global Trust
Form 10-K for the year ended December 31, 2004
File No. 000-22887

Dear Mr. O`Brien:

      We have reviewed the above referenced filings and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents.  As such, all persons who are
responsible
for the adequacy and accuracy of the disclosure are urged to be
certain that they have included all information required pursuant
to
the Securities Exchange Act of 1934.

Where indicated, we think you should revise your documents in
response to these comments.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
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 10-K for the year ended December 31, 2004


1. Please amend your Form 10-K for the fiscal year ended December
31,
2004 to include your Report of Independent Registered Public
Accounting Firm indicating the name of the accountants as well as
the
city and state of the office that performed the audit for KPMG
LLP.

*    *    *    *

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 file your response on EDGAR.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

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 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.

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 do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

You may contact Kelly McCusker, Staff Accountant, at (202) 824-
5453
or the undersigned at (202) 942-1993 if you have questions.


						Sincerely,



      Jorge Bonilla
      Senior Staff Accountant


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JWH Global Trust
April 27, 2005
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