1555 Palm Beach Lakes Boulevard, Suite 310 West Palm Beach, FL 33401-2327 Tel: (561) 478-7077 Fax: (561) 659-0701 www.harriscramer.com Michael D. Harris, Esq. mharris@harriscramer.com |
September 28, 2007
VIA EDGAR
Jennifer R. Hardy, Esq.
Legal Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E., Mail Stop 7010
Washington, D.C. 20549
Re:
GelTech Solutions, Inc.
File Number: 333-144736
Dear Ms. Hardy:
On behalf of our client, GelTech Solutions, Inc., we are filing via EDGAR Amendment No. 1 to the Form SB-2. In response to the Staff’s comment letter of August 7, 2007, the Company is now offering for sale on a best-efforts basis 450,000 shares of its common stock at $0.66 per share. Following completion of the primary offering, the secondary offering by the selling shareholders may commence. We trust that this satisfies the Staff’s comment.
Appropriate changes have been made throughout this prospectus to give effect to this primary offering, as well as necessary updating, including inclusion of the audited financial statements for the year ended June 30, 2007.
If you have any questions, please call me at the above number.
Very truly yours,
/s/ Michael D. Harris
Michael D. Harris
MDH/cdv
cc:
Mr. Michael Cordani
Mr. David Rosenfeld
(Via Email)