Mail Stop 3561
								July 27, 2005

Mr. Steven Malone, CEO
Findex.com, Inc.
11204 Davenport Street, Suite 100
Omaha, NE 68154

Re:	Findex.com, Inc.
	Item 4.02 Form 8-K
      Filed 7/22/05
	File No. 000-29963

Dear Mr. Malone:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document 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.
In some of our comments, we may ask you to provide us with more
information so we may better understand your disclosure.  After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

1. In the first paragraph of your disclosure, please delete the
phrase in the first sentence which states "not to be materially
misleading" with respect to your financial statements.  We believe
that it would be more appropriate to replace this language with a
phrase such as "to comply with generally accepted accounting
principles".  This revision is requested because the Division of
Corporation Finance does not determine whether financial
statements
are materially misleading.

2. Because the comparative financial statements for the year ended
December 31, 1999 will be included in the restated Form 10-KSB for
the year ended December 31, 2000, you may elect to restate the
financial statements for both years in the revised 10-KSB for the
year ended December 31, 2000.  If you elect to do this, please
delete
the reference in parentheses regarding the filing of the December
31,
1999 financial statements on Form 8/K/A, since this filing will
not
be amended.  However, please note that the reference to the period
itself should be retained.

3. Please tell us how you determined that the quarterly periods
prior
to June 30, 2002 would not be affected by the restatements.  Also,
it
would appear that the financial statements for the year ended
December 31, 2001 would also need to be restated, due to the
effect
on retained earnings for restatements relating to prior periods.
Please revise your disclosures accordingly, or tell us why you
believe that no revisions are required.

4. With regards to your bullet point disclosures regarding the
recommended changes, please consider whether including separate
categories for each distinct type of change may be appropriate.
For
example, some of the changes noted will result in a restatement of
the statement of operations for the respective period, whereas
other
proposed changes will not affect the reported net income or loss,
but
will result in a reclassification between line items, or a change
in
the description of a line item.

5. Please revise your disclosures to clarify the exact nature of
the
following items:
* The error correction noted in the first bullet point.  Please
clarify how the transaction was originally recorded and how it
will
be recorded following the restatement.
* Each of the items that were previously characterized as "non-
recurring items".  Please expand your disclosure to provide more
details regarding the nature of each adjustment or expense.  In
addition, please disclose how each transaction is classified in
the
statement of operations.

6. We note that you intend to file restated financial statements
for
the periods noted.  Please tell us how, and when, you expect to
file
them.  If not currently known, please state this in your
disclosure.

      As appropriate, please amend your filing and respond to
these
comments within five business days or tell us when you will
respond.
You may wish to provide us with marked copies of the amendment to
expedite our review.  Please furnish a cover letter with your
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  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 filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 filing;

* staff comments or changes to disclosure in response to staff
comments 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.

	If you have any questions, please call Carlton Tartar, Staff
Accountant, at (202) 551-3387, or Tia Jenkins, Senior Assistant
Chief
Accountant, at (202) 551-3871.

							Sincerely,



							Carlton Tartar
							Staff Accountant


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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0306

         DIVISION OF
CORPORATION FINANCE