By Edgar "CORRESP" BY FACSIMILE -- 202- 942-9544 February 11, 2005 Loryn Zerner Securities and Exchange Commission 450 Fifth Street, N.W. Washington, DC 20549 Re: Alliance Distributors Holding Inc. SB-2/A Filed December 23, 2004 Registration Statement No. 333- 121607 Dear Ms. Zerner: Alliance Distributors Holding Inc. hereby requests acceleration of its above-referenced registration statement on Form SB-2/A so that it may become effective at 12:00 PM EST, February 11, 2005 or as soon thereafter as is practicable. Very truly yours, Alliance Distributors Holding Inc. By: Jay Gelman Chief Executive Officer