MAIL STOP 3561
      December 6, 2005

Robert Hanks, Chief Executive Officer
Harbor Acquisition Corporation
One Boston Place, Ste. 3630
Boston, MA 02108

      Re:	Harbor Acquisition Corporation
   Amendment No. 4 to Registration Statement on
   Form S-1
   Filed November 25, 2005
   File No. 333-126300

Dear Mr. Hanks,

      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
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 Summary, page 1

1. We note your response to comment seven that you will "focus
your
efforts exclusively on acquiring" a company in the industrial or
consumer products sectors and as such you have removed the risk
factor titled "our officers and directors may not have significant
experience or knowledge of he industry of a target business that
operates outside of the industrial and consumer product sectors."
We
do not understand how that risk does not exist in light of your
statement on page one that your efforts "will not be limited to a
particular industry."  Either they are or they are not limited.
Since it appears they are not limited to the areas of your
management`s experience, you should not structure your disclosure
as
if there is zero possibility that you will acquire a non
industrial
or consumer products company.  Please revise your disclosure
accordingly.

2. Throughout this document, you state numerous beliefs or
promotional statements that only apply if you seek a company in
the
industrial or consumer products sectors.  Because you are not
limited
to those activities, you should revise your disclosure to clarify
that any perceived benefits or advantages are moot if you elect to
acquire a company outside of the initial sector focus.

Use of Proceeds, page 20

3. We note your response to comment 11 and the revision in the
table
and the additional footnotes.  It appears that footnote one and
two
show that your allocation of expenses is overlapping.  You
reserved
an amount for due diligence under both footnote one and two.  You
also reserve payments to third-party consultants and other
professionals under footnote one and two.  Please revise to
precisely
outline your use of the proceeds not held in trust.

4. We note the additional disclosure on page 21 that management
has
experience that "involves raising pools of money with no
investment
target or list of potential candidates, searching for companies to
invest in or acquire from scratch, conducting due diligence, and
structuring and completing transactions."  Please revise your Item
401 of Regulation S-K disclosure to highlight this experience.

5. Please revise to clarify which line item the payment to of
$75,000
to your CEO and president would be allocated to.

Proposed Business, page 27

6. We note your response to comment 12.  In light of the fact that
you "will not be limited to a particular industry," the prior
comment
still applies.  The noted disclosure on page one combined with the
fact that you only "intend" to search for companies within your
initial focus, leaves open the possibility for you to acquire a
company outside such focus.  Please revise to discuss your
intended
search process in more detail since you are able to acquire
companies
outside of management`s expertise.  Revise to clarify if there is
a
time frame or monetary amount used that will trigger your search
of
companies not in the consumer or industrial products sectors.
Revise
to explain how you will evaluate companies that management has no
experience in.  Also, discuss the risks associated with
management`s
ability to look outside of their expertise.

7. Please revise to reconcile the second sentence on page 29 that
beings "subject to limitations that a target business must be in
the
industrial and consumer products sectors" with your disclosure on
page one that your efforts "will not be limited to a particular
industry."  We also direct your attention to disclosure on page 29
that "although [you] will focus exclusively on acquiring an
operating
business in the industrial or consumer products sector, we may
acquire companies operating in any industry [you] chose."

Principal Stockholders, page

8. We note the additional disclosure in response to comment 17.
We
note that Messrs. Hanks and Dullum have agreed to purchase
warrants
in the market after "the later of the date separate trading of the
warrants has commenced or 60 days after the closing of this
offering."  Please revise to reconcile that with your response
that
such purchases or bids will not "occur until 60 calendar days
following the end of the restricted period."

Other Terms, page 55

9. We note that Ferris, Baker Watts will purchase the warrants on
behalf of those obligated by the warrant purchase agreement.
Please
advise if Ferris, Baker Watts is able to purchase your securities
in
the market for their own account.  We also note that Ferris, Baker
Watts will be able to have a designee (who need not be the same
person each time) present at all meetings of the board of
directors
and that such designee will receive the same notices and
communications as your directors do.  Please advise if Ferris,
Baker
Watts will possess or may otherwise have access to non-public
information as a result of this arrangement when it engages in
warrant purchases for the undersigns or itself, and if so, clarify
Farris Baker Watts` ability to act as the purchaser under the
warrant
repurchase agreements consistently with the provisions of Section
10(b) of the Securities Exchange Act of 1934 and the rules
promulgated thereunder.  We may have further comment.

Closing Comments

      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.

      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.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.


      You may contact Carlton Tartar (202) 551-3387 if you have
questions regarding comments on the financial statements and
related
matters.  Questions on other disclosure issues may be directed to
Duc
Dang at (202) 551-3386.

						Sincerely,



						John Reynolds
      Assistant Director

Cc:  	Andrew Myers
	Fax #  (617) 523-6215

Robert Hanks, Chief Executive Officer
Harbor Acquisition Corporation
December 6, 2005
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