JULIE M. KAUFER
                                                  310.728.3313/fax: 310.728.2313
                                                  jkaufer@akingump.com


                                January 25, 2005


VIA EDGAR AND OVERNIGHT DELIVERY


Jay S. Mumford, Esq.
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549-0306

       Re:  Universal Detection Technology
            Amendment No.3 to Registration Statement on Form SB-2 filed on
            December 23, 2004 File No. 333-117859

Dear Mr. Mumford:

     On behalf of Universal Detection Technology, a California corporation, we
hereby respond to the comment letter of the Securities and Exchange Commission
dated January 4, 2005. In our letter, we refer to Universal Detection Technology
as the "COMPANY," to Amendment No. 4 to the Registration Statement as the
"REGISTRATION STATEMENT," to the Securities and Exchange Commission as the
"COMMISSION," to the Staff of the Commission as the "STAFF," and to the
Securities Act of 1933, as amended, as the "ACT." Paragraph numbering used for
each response set forth below corresponds to the paragraph numbering used in the
Staff's letter. The references to page numbers of the Registration Statement are
references to the pages of the marked version of the Registration Statement, a
copy of which we have enclosed.

1.   GIVEN THAT YOU HAVE COMPLETED YOUR FOURTH FISCAL QUARTER, INCLUDE A "RECENT
     DEVELOPMENTS" SECTION SUMMARIZING ANY MATERIAL CHANGES IN YOUR OPERATING
     RESULTS AND/OR FINANCIAL CONDITION DURING THE QUARTER. ALSO, UPDATE TO
     REFLECT ANY OTHER MATERIAL CHANGES THAT TOOK PLACE DURING THE LATEST
     QUARTER. FOR EXAMPLE, UPDATE ITEM 26 ON PAGE II-1 IF NECESSARY.

     We have complied with the Staff's comment. Please refer to pages 2 of the
Registration Statement.

2.   WE NOTE YOUR RESPONSE TO COMMENT 8 REGARDING REQUIRING AN ADDITIONAL TEST
     TO DETECT ANTHRAX AFTER YOUR DEVICE DETECTS AN INCREASE IN SPORES. PLEASE
     REVISE THE PROSPECTUS SUMMARY DISCLOSURE TO CLARIFY THAT YOUR DEVICE ONLY
     DETECTS AN INCREASE IN SPORE COUNT, WHICH MAY OR MAY NOT BE ANTHRAX, AND
     THAT AN ADDITIONAL TEST IS




Jay S. Mumford, Esq.
January 25, 2005
Page 2




     REQUIRED TO DETECT THE PRESENCE OF ANTHRAX. THIS IS PARTICULARLY IMPORTANT
     SINCE YOU REFER TO YOUR PRODUCT AS AN "ANTHRAX SMOKE DETECTOR," WHEN IN
     FACT IT DOES NOT SPECIFICALLY DETECT ANTHRAX.

     We have complied with the Staff's comment. Please refer to page 1 of the
Registration Statement.

AUDIT COMMITTEE INQUIRY - PAGE 15

3.   DISCLOSE THE AMOUNT OF COMPANY FUNDS INVOLVED.

     We have complied with the Staff's comment. Please refer to page 14 of the
Registration Statement.

4.   PLEASE UPDATE YOUR EXECUTIVE OFFICER COMPENSATION FOR 2004 IN YOUR NEXT
     AMENDMENT.

     We have complied with the Staff's comment. Please refer to page 28 of the
Registration Statement.

BUSINESS

5.   IN AN APPROPRIATE LOCATION, DISCUSS THE SECURE WRAP PURCHASE ORDER, AND
     DISCLOSE THE PURCHASE PRICE PER UNIT.

     We have complied with the Staff's comment. Please refer to pages 13 and 24
of the Registration Statement.

MANAGEMENT

6.   EXPAND TO IDENTIFY THE "VICE PRESIDENT OF GLOBAL STRATEGY," PROVIDE
     RELEVANT BIOGRAPHICAL INFORMATION, AND DISCLOSE THE MATERIAL TERMS OF THE
     EMPLOYMENT AGREEMENT. FILE THE AGREEMENT AS AN EXHIBIT.

     We have complied with the Staff's comment. Please refer to pages 27, 28, 31
and Exhibit 10.22 to the Registration Statement.




Jay S. Mumford, Esq.
January 25, 2005
Page 3


7.   UPDATE THE DIRECTOR COMPENSATION INFORMATION. WE NOTE THE DISCLOSURE ON
     PAGE F-43.

     We have complied with the Staff's comment. Please refer to page 28 of the
Registration Statemen.

     If you have questions or require any additional information or documents,
please do not hesitate to contact me at (310) 728-3313.

                                                   Very truly yours,



                                                   /s/ Julie M. Kaufer
                                                   ----------------------------
                                                   Julie M. Kaufer



Enclosure