<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>2
<FILENAME>ctd20058kjmcoletter.txt
<DESCRIPTION>CTD HOLDINGS -- 07-2005 8-K -- JMCO. LETTER
<TEXT>
                                  July 19, 2005

Securities and Exchange Commission
450 5th Street, N.W.
Washington DC 20549


   RE:      Form 8-K to be filed July 19, 2005
            CTD Holdings, Inc.
            Commission File No. 0-24930

Dear Sirs:

         Please be advised  that we have been  provided  with a copy of Form 8-K
which the  Registrant,  CTD Holdings,  Inc.,  has stated that it intends to file
today.  We agree  with the  statements  made in the Form 8-K.  We consent to the
filing of this letter as an exhibit to said Form 8-K.

                                               JAMES MOORE & CO., P.L.

                                               By:  /s/ Roger N. Swanger
                                               ----------------------------

Gainesville, Florida
July 19, 2005
</TEXT>
</DOCUMENT>