July 30, 2019

Dominique Schulte
Chief Executive Officer
Janel Corporation
303 Merrick Road
Lynbrook, New York 11563

       Re: Janel Corporation
           Amendment No. 1 to Form 8-K
           Filed July 24, 2019
           File No. 333-60608

Dear Ms. Schulte:

      We have reviewed your filing and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your
disclosure.

       Please respond to this comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Amendment No. 1 to Form 8-K Filed July 24, 2019

Item 4.02

1.    We understand from your disclosures that you discovered errors related to
your
      application of ASC 605-45 impacting your financial statements for your
fiscal years ended
      September 30, 2016 and 2017, and the subsequent interim periods through
June 30, 2018.
      We further understand from your disclosures that you recently concluded
these errors do
      not require the restatement of your financial statements. We further note
that while you
      have not quantified the impact of correcting these errors on your
financial statements for
      the fiscal year ended September 30, 2016, your recently filed Form 10-K
for the fiscal
      year ended September 30, 2018 indicates that the error correction reduced
your total
      revenue by more than 20% for each of the fiscal year ended September 30,
2017 and the
      nine months ended June 30, 2018. We have the following comments:

            Please tell us the quantified impact of the error correction on
your Global Logistic
            Revenue and Forwarding Expense for the year ended September 30,
2016.
 Dominique Schulte
Janel Corporation
July 30, 2019
Page 2


             In light of the magnitude of the change in your Global Logistic
Revenue, Total
             Revenue, and Forwarding Expense resulting from this error
correction, please tell us in
             detail how you concluded this error correction was immaterial and
should not be
             treated as a restatement of your previously published financial
statements. Since it
             appears from your recently filed Form 10-K that you performed an
analysis under
             SAB Topics 1:M and 1:N, please provide us with that analysis to
assist us in
             understanding your view.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

      You may contact Yong Kim, Staff Accountant, at 202-551-3323 or Jennifer
Thompson,
Accounting Branch Chief, at 202-551-3737 with any questions.




FirstName LastNameDominique Schulte                           Sincerely,
Comapany NameJanel Corporation
                                                              Division of
Corporation Finance
July 30, 2019 Page 2                                          Office of
Consumer Products
FirstName LastName