Mail Stop 3561

							November 9, 2005

Thomas W. Itin
Chairman
CompuSonics Video Corporation
37735 Enterprise Ct., Suite 600-B
Farmington Hills, MI  48331



	RE:	CompuSonics Video Corporation
		Item 4.01 Form 8-K filed November 9, 2005
		File No. 0-14200


Dear Mr. Itin:

          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 comments are inapplicable or a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.

          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 any other aspect
of
our review.  Feel free to contact us at the telephone numbers
listed
at the end of this letter.
1. Please revise to include a letter from your former accountants
complying with the requirements of Item 304(a)(3) of Regulation S-
B.
2. Please revise the first paragraph to state if J.L. Stephan was
dismissed or if they resigned or declined to stand for re-
election.
We do not believe the word "replaced" satisfies the requirements
of
Item 304(a)(1)(i) of Regulation S-B.  Also, revise to state the
date
of this event.  We do not believe the engagement date of the new
auditors satisfies this requirement.  Since the dismissal of
former
accountants and the engagement of new accountants are two separate
events, please consider revising your filing to report these
matters
in separate paragraphs.




Thomas W. Itin
CompuSonics Video Corporation
November 9, 2005
Page 2

3. Please revise to expand the second paragraph to state if there
were any modifications to the auditors report for either of the
past
two years.  In this regard, we note that an unqualified report may
contain modifications.  See Item 304(a)(1)(ii) of Regulation S-B.
4. Please expand the fourth paragraph to define the period for
which
there were no disagreements.  We believe your disclosure should
state
that there were no disagreements for the two most recent fiscal
years
and the subsequent interim period through October 11, 2005, if
true.
Please revise or advise.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing 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.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosures in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

?	the company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

	The amendment requested above should be filed within five
business days from the date of this letter or we should be advised
by
that date when they will be filed.  Please note that the initial
filing was required to be filed within 4 business days from the
date
of the event.  Please file your response to these comments as an
EDGAR correspondence file at the same time as you file the Form 8-
K/A.  The Form 8-K/A should include your Commission file number on
the cover page.  Any questions regarding the above should be
directed
to Robert Burnett at (202) 551-3330, or in his absence, to me at
(202) 551-3841.

							Sincerely,


							Michael Moran
						            Branch Chief


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