ARKADOS GROUP, INC.

220 Old New Brunswick Road, Suite 202

Piscataway, NJ 08854

February 5, 2007

VIA EDGAR AND FEDERAL EXPRESS

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attn:      Robert Telewicz

Senior Staff Accountant

Yolanda Crittendon

Staff Accountant

Re:Arkados Group, Inc. (the “Company”)

Form 10-KSB for Fiscal Year Ended May 31, 2006

Form 10-QSB for Fiscal Quarter Ended August 31, 2006

Ladies and Gentlemen:

In connection with your consideration of our responses to the Staff’s comments of January 9, 2007, we acknowledge that:

·   Arkados 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

·   Arkados 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.

Thank you for your attention.

Very truly yours,

/s/ Oleg Logvinov

Oleg Logvinov

Chief Executive Officer