SICHENZIA ROSS FRIEDMAN FERENCE LLP
                                ATTORNEYS AT LAW
                                [GRAPHIC OMITTED]

                                             May 9, 2006

Mail Stop 6010
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549

Attention:   Donald C. Hunt; Peggy A. Fisher

      Re:   Universal Detection, Inc.
            Registration Statement on Form SB-2 filed February 14, 2006 File No.
            333-131849

Ladies and Gentlemen:

      The  following  addresses  the  comment  of  the  reviewing  Staff  of the
Commission  as set forth in the comment  letter of March 1, 2006 relating to the
Registration  Statement  on Form  SB-2 (the  "filing")  of  Universal  Detection
Technology,  Inc.  ("Universal  Detection" or the  "Company").  On behalf of the
Company, we respond as follows.

      As  requested,  the  Company has amended  the  Registration  Statement  to
include updated financial  information.  The amended  Registration  Statement is
being filed concurrently with the filing of this letter.


      Should you have any  questions,  please do not  hesitate  to  contact  the
undersigned at 212-930-9700. Thank you.



                                              Very Truly Yours,

                                              /s/ Darrin Ocasio
                                              -----------------
                                              Darrin Ocasio