PuraMed BioScience Inc.
1326 Schofield Ave. P.O. Box 677
Schofield, WI 54476
Phone: 715.359.6373
Fax: 715.355.3093
eMail:jhiggins@puramedbioscience.com
United States Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549
Attn: Staci Shannon, Staff Accountant
Date: February 15, 2011
Re: PuraMed BioScience, Inc – Response to SEC Letter Dated February 11, 2011
Dear Commission:
Regarding your letter to PuraMed BioScience Inc. (the “Company”) of February 11, 2011, the following responses are keyed to the paragraph numbers in your comment letter:
Form 10-K for Fiscal Year Ended June 30, 2010
SEC Comment #1 (Item 9A. Controls and Procedures, page 14)
The company will amend our June 30, 2010 10-K filing to include management’s annual report on internal control over financial reporting pursuant to Item 308 of regulation S-K.
The omission of management’s report on internal control over financial reporting did not impact its conclusions regarding the effectiveness of our disclosure controls and procedures.
SEC Comment #2 (Item 15. Exhibits and Financial Statement Schedules Exhibits 31.1 and 31.2)
The company will amend our June 30, 2010 10-K filing to revise our certifications included in Exhibits 31.1 and 31.2 to conform to the language of Item 601 (b)(31) of Regulation S-K, including the internal controls language of Paragraph 4 of that Item and eliminate references to small business issuer.
The Company acknowledges that:
| i) | the Company is responsible for the adequacy and accuracy of disclosure in the filings; |
| ii) | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and |
| iii) | the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
The company plans on filing the amendment to our June 30, 2010 10-K with the corrections noted above by 2/28/2011.
Sincerely,
/s/ James Higgins, Chief Financial Officer
of PuraMed BioScience, Inc.
