STOECKLEIN LAW GROUP, A PROFESSIONAL CORPORATION
PRACTICE LIMITED TO FEDERAL SECURITIES
EMERALD PLAZA | Telephone: (619) 595-4882 |
402 West Broadway | Facsimile: (619) 595-4883 |
Suite 400 | email: djs@slgseclaw.com |
San Diego, California 92101 | web: www.slgseclaw.com |
January 24, 2006
Jill S. Davis
Division of Corporate Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: | Integrated Environmental Technologies, Ltd. |
| Your Letter of December 21, 2005 | |
Form 10-KSB for Fiscal Year Ended December 31, 2004, as amended
Filed March 30, 2005 and December 9, 2005
| Form 10-QSB for Fiscal Quarters |
Ended March 31, 2005, June 30, 2005 (as amended)
and September 30, 2005
| Filed May 17, 2005, August 19, 2005, December 9, 2005 |
| And November 14, 2005 | |
| Response Letters Dated October 11, 2005 and December 7, 2005 |
| File No. 0-26309 | |
| Form SB-2 | |
| Filed October 3, 2005 |
| File No. 333-128759 | |
| | | |
Dear Ms. Davis:
This correspondence is in response to your letter dated December 21, 2005 in reference to our filings listed above on behalf of Integrated Environmental Technologies, Ltd. (“IET”).
In response to your request we have keyed our responses to your comment items in their original numeric order and provided for a notation of the location of the changes in the revised and amended filings.
Integrated Environmental Technologies, Ltd.
January 24, 2006
Page 2
Form SB-2, filed October 3, 2005
General
| 1. | Please update the interim financial statements and the related management’s discussion and analysis discussion as needed. Refer to Item 310(g) of Regulation S-B. |
Response:
We have complied with your request and updated the interim financial statements and the related management’s discussion and analysis discussion.
| 2. | Please update your independent auditor’s consent. |
Response:
We have complied with your request and updated our independent auditor’s consent.
In addition, we added additional selling security holders and updated some of the disclosure in the SB-2/A No. 1.
| In connection with our responses to your comments above, we acknowledge that: |
| • | we are responsible for the adequacy and accuracy of the disclosure in the filing; |
| • | staff comments or changes to our disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
| • | we may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States. |
| Please advise if we can be of any further assistance. |
Yours truly,
/s/ Donald Stoecklein
Donald J. Stoecklein
/rv