GELTECH SOLUTIONS, INC.
1460 Park Lane South
Suite 1
Jupiter, FL 33458
December 20, 2007
Via EDGAR
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E., Mail Stop 7010
Washington, D. C. 20549
Attention:
Jennifer R. Hardy
Legal Branch Chief
Re:
GelTech Solutions, Inc./SB-2 Correspondence
Registration Statement on Form SB-2/Amendment No. 3
File No. 333-144736
Dear Ms. Hardy:
In accordance with Rules 460 and 461 promulgated pursuant to the Securities Act of 1933, GelTech Solutions, Inc. (the "Company") is hereby requesting that the Company's Registration Statement on Form SB-2 referenced above be made effective on December 27, 2007, at 9:30 a.m., or as soon thereafter as may be practicable.
The Company acknowledges that:
·
should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
·
the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
·
the Company may not assert the staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
| Very truly yours, |
|
|
| /s/ MICHAEL CORDANI |
| Michael Cordani |
| Chief Executive Officer |
cc:
Michael D. Harris, Esq.