THE LAW OFFICE OF
CONRAD C. LYSIAK, P.S.
601 West First Avenue, Suite 903
Spokane, Washington 99201
(509) 624-1475
FAX: (509) 747-1770
EMAIL: cclysiak@lysiaklaw.com
February 14, 2013
Ms. Maryse Mills-Apenteng
Special Counsel
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-3561
| RE: | HDS International Corp. |
| | Form S-1/A-1 Registration Statement |
| | File No. 333-182573 |
Dear Ms. Mills-Apenteng:
In response to your letter of comments dated February 13, 2013 please be advised as follows:
Prospectus Cover Page
1. The disclosure has been revised as requested.
2. The revision has been made as requested.
Risk Factors
3. The information requested has been provided.
Business
4. The disclosure requested has been provided.
5. The information requested has been provided.
Executive Compensation
6. The information has updated through December 31, 2012 as requested.
Selling Shareholders
7. The information requested has been provided.
Exhibits
Legal Opinion
8. The legal opinion has been revised as requested.
| Ms. Maryse Mills-Apenteng |
| Securities and Exchange Commission |
| RE: | HDS International Corp. |
| | Form S-1 Registration Statement |
| | File No. 333-182573 |
| February 14, 2013 |
| Page 2 |
Legal Opinion
9. The legal opinion has been revised as requested.
Undertakings
10. The undertakings have been revised as requested.
| Yours truly, |
|
| The Law Office of Conrad C. Lysiak, P.S. |
|
| BY: | CONRAD C. LYSIAK |
| | Conrad C. Lysiak |
CCL: hdw
cc: HDS International Corp.