Mail Stop 0308 							November 22, 2004

VIA U.S. MAIL AND FACSIMILE

Thomas G. Miller
President
S. E. Asia Trading Company, Inc.
1545 E. Interstate 30
Rockwall, Texas 75087

Re:	S. E. Asia Trading Company, Inc.
Amendment No. to Registration Statement on Form SB-1
File No. 333-118898
Filed November 10, 2004

Dear Mr. Miller:

We have reviewed your amended 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 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 numbers listed at the end of this
letter.

Prospectus Inside Cover Page, page 1
1. We note in your response to our prior comment 4 that you intend to
apply for listing on the NASDAQ Bulletin Board.  Advise us when you
intend to list your securities, and delete the reference to the
"NASDAQ" Bulletin Board here and throughout the registration
statement.  Instead you should refer to the over-the-counter bulletin
board.

Prospectus Summary, page 2
2. You refer to page 15, "Plan of Operations."  However, it appears
the "Plan of Operation" section begins on page 14.  Please revise or
advise.

Summary Financial Data, page 3
3. We note your response to our prior comment 6.  Relocate the
disclosure on yours having received a going concern opinion from this
section to the "Our Company" sub-section of the Prospectus Summary on
page 2.  Also, for clarification, add to the disclosure that your
business conditions have raised "substantial doubt" as to your
continuance as a going concern that you need to continue as a going
concern if your business is to succeed, and that you cannot assure
investors that you will be able to generate sufficient revenues to
achieve profitability or even survive.

Risk Factors

"If a public trading market for our common stock materializes, we will
be classified as a `penny stock`...," page 6
4. We note your response to our prior comment 12.  Explicitly state
that the penny stock rules may adversely affect the ability of both
the broker-dealers to sell your securities as well as the purchasers
of your securities to sell them in the secondary market.

Plan of Distribution, page 8
5. We note your response to our prior comment 22.  Represent in the
registration statement that you will not cash those checks unless and
until you raise the minimum subscription amount, that you will not pay
any interest on the funds received while they are held in your
attorney`s safe, and that you will take reasonable care not to
commingle the funds received with any other monies.

Use of Proceeds, page 9
6. On page 10, you state that you will pay Mr. Miller a salary of
$2,500 per month and twenty percent of profits after the company has
reached profitability.  However, the disclosure on page 17 does not
make clear when Mr. Miller will start to earn a salary.  Please
clarify if he is currently earning $2,500 per month.  Also, clarify
whether you mean that Mr. Miller will receive 20% of net income or
whether you are using another measure to assess profitability.

Business Strategy, page 11
7. You state that you plan to add "at least" one new store during the
next twelve months.  To be consistent with your stated use of
proceeds, state that you will add only one more store at the most.

Management`s Discussion and Plan of Operations

Generating Sufficient Revenue, page 15
8. Provide justification for your belief that "more and more people"
are responding to your advertising, including recent sales figures
that you ascribe specifically to effects of your advertising.
9. We note your response to our prior comment 38.  Specifically state
whether you will be able to generate sufficient cash to sustain your
operations for the next 12 months in the event you fail to raise the
minimum offering amount through the sale of these securities.

Financial Needs, page 15
10. You twice state an average gross profit of 75%.  Please
supplementally reconcile your expected 75% gross profit to the actual
62% gross profit realized from inception through September 30, 2004.
Please note that a higher gross profit estimate would represent a
forecast and would be subject to the Commission policy on projections
set forth in Item 10 (d) of Regulation S-B.  Please consider whether
such estimate is supportable or remove it from the discussion.  We may
have further comment.
11. Provide us supplementally an annotated copy of the article on
growth in Rockwall county to which you refer.  Also, substantiate your
claim that this growth is primarily driven by "young urbanites and
families," which comprise your targeted customer base.

Significant Parties, page 18
12. For each record holder of at least 5% of your securities, disclose
the exact percentage that particular individual owns at present and
that the individual will own after the offering in either case of the
minimum subscription amount or the maximum subscription amount being
raised.  Also the disclosure in the Principal Shareholders table
should refer to owners of 5% or more of your securities.  See Item
403(a) of Regulation S-B.
13. Disclose the middle initial of Mr. Charles Smith.

Financial Statements for the period January 28, 2004 (Inception)
through May 31, 2004
14. In accordance with Item 310(a) of Regulation S-B "small business
issuers shall file an audited balance sheet as of the end of the most
recent fiscal year, or as of a date within 135 days if the issuers
existed for a period less than one fiscal year, and audited statements
of income, cash flows and changes in stockholders` equity for each of
the two fiscal years preceding the date of such audited balance sheet
(or such shorter period as the registrant has been in business)."  The
financial statements for the period January 28, 2004 (Inception)
through September 30, 2004 must be audited and accompanied by an audit
report and consent.

Financial Statements for the period January 28, 2004 (Inception)
through September 30, 2004

Balance Sheet as of September 30, 2004
15. The total current assets figure does not foot.  Please revise.

Statement of Loss for the period January 28, 2004 (Inception) through
September 30, 2004
16. Please add a description for the subtotal that is titled "loss
from operations" in your 5/31/04 financial statements.
17. The loss from operations and net loss line items do not foot.
Please revise.
18. The loss on sale of marketable securities line item balance does
not agree to the statement of cash flows and is different than the
statement of loss for the period January 28, 2004 (Inception) through
May 31, 2004.  Please revise or advise.

Statement of Cash Flows for the period January 28, 2004 (Inception)
through September 30, 2004
19. The non-cash disclosure states that marketable securities valued
at $102,000 were issued for stock.  Note 5 also indicates that you
issued 620,000 shares of stock for marketable securities valued at
$102,000.  This is inconsistent with the $82,000 included in the
statement of stockholders` equity.  Please revise or advise.

Note 1. Summary of Significant Accounting Policies
20. Please include a phrase similar to "nature of business" in the
title of note 1.  For example the title of note 1 may read "Nature of
Business and Summary of Significant Accounting Policies."
21. Please disclose the line item in which you include amounts paid to
you by customers for shipping and handling.  See EITF-00-10.
22. The last sentence of the revenue recognition summary implies that
there is not a reserve for returns given the return policy described.
It appears that the return policy does not exempt you from reserving
for returns.  If no return reserve exists due to immateriality, you
may provide disclosure to that effect.  Please revise or advise.

Item 5.  Exhibits
23. We note your response to our prior comment 63.  Please renumber
your exhibits in the exhibit list so they correspond to the numbers in
Item 601 of Regulation S-B.  For example, your articles of
incorporation should be filed as exhibit 3.1, by-laws as exhibit 3.2,
the forms of subscription agreements as exhibits 4.1 and 4.2, the
revolving agreement as exhibit 10.1, the auditor`s consent as exhibit
23.1, the attorney`s consent as exhibit 23.2, and the legality opinion
as exhibit 5.1.

*	*	*	*	*

As appropriate, please amend your registration statement in response
to these comments.  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 supplemental 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.

You may contact Adam Phippen, Staff Accountant, at (202) 824-5549 or
James Allegretto, Senior Assistant Chief Accountant, at (202) 942-
1885, if you have questions regarding comments on the financial
statements and related matters.  Please contact Pradip Bhaumik,
Attorney-Advisor, at (202) 942-1776, or Ellie Quarles, Special
Counsel, at (202) 942-1859, or me at (202) 942-1900 with any other
questions.


Sincerely,




H. Christopher Owings
Assistant Director



cc:	J. Hamilton McMenamy, Esq.
	Law Offices of J. Hamilton McMenamy PC
	1450 Meadowpark Building
	10440 North Central Expressway
	Dallas, Texas 75231
S. E. Asia Trading Company, Inc.
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