Mail Stop 0308 							December 8, 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.
      Registration Statement on Form SB-1
      File No. 333-118898, Amended December 3, 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.

Use of Proceeds, page 10
1. We note your response to our prior comment 6.  You state on
page
11 that you "will compensate Mr. Miller after the company has
reached
profitability."  But in the next sentence we note that "Mr. Miller
has been receiving his salary since February 2004."  However, as
disclosed on page 15, the maximum sales figure you have achieved
so
far has been $3,818 in a month and that "the majority of funds are
invested in inventories."  Reconcile these statements and explain
whether you have achieved consistent profitability since February
2004 and whether the profit amounts to at least $2,500 a month,
which
is Mr. Miller`s monthly salary.  If not, explain on what basis Mr.
Miller has been drawing his salary, especially when you state
unequivocally on page 11 that "his compensation will be based on
performance and profitability."  Please advise.

Management`s Discussion and Plan of Operations, page 15
2. We note your response to our prior comment 9.  You state on
page
16 that "the Company`s initial financing needs can and will be met
even if the minimum offering amount is raised."  Explicitly state
whether or not you will be able to obtain sufficient cash to
sustain
your operations for the next 12 months in the event you cannot
raise
the minimum offering amount.  We reissue the comment.

Principal Shareholders, page 18
3. We note your response to our prior comment 12.  You state that
your principal shareholders table lists the persons who own "more
than 10%" of the outstanding common stock.  Revise the statement
to
state that you have listed all owners of "5% or more" of your
securities.  Please refer to Item 403(a) of Regulation S-B.

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

Note 1. Summary of Significant Accounting Policies

4. We are unclear on how you complied with comment number 21
included
in our letter dated November 22, 2004.  Please disclose the line
item
in which you include amounts paid to you by customers for shipping
and handling.  See EITF-00-10.  Please revise or advise with
specific
reference to the added disclosure.
5. We assume your fiscal year end is December 31.  If our
assumption
is incorrect, you should supplementally advise and disclose your
fiscal year end.


*	*	*	*	*


      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, 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

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S.E. Asia Trading Company, Inc.
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