Health Advance Inc.
3651 Linden Road, Suite D155
Las Vegas, NV 89103
April 6, 2015
VIA EDGAR
Jennifer Thompson,Accounting Branch Chief
Division of Corporation Finance
Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549
Amendment No. 1 to Form 10-K for the Fiscal Year Ended
July 31, 2014
Filed March 20, 2015
Response dated March 20, 2015
File No. 333-177122
Dear Ms. Thompson:
We are in receipt of your comment letter dated April 2, 2015 regarding the above referenced filing. As requested in your letter, we have provided below response to the comment raised by the Staff. For your convenience, the matter is listed below, followed by the Company’s responses:
Amendment No. 1 to Form 10-K for the Fiscal Year Ended July 31, 2014
General
1. | The representations provided in your response letter to us dated March 20, 2015 were inconsistent with the representations we requested you provide to us in our letter dated March 12, 2015. Please provide a written statement from the company using the exact language that we previously requested, i.e.: |
· | the company is responsible for the adequacy and accuracy of the disclosure in the filing; |
· | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
· | 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. |
RESPONSE:In response to Staff’s comment hereof and those in connection to Amendment No. 1 on Form 10-K/A filed with the Commission on March 20, 2015, the Company acknowledges that:
· | the Company is responsible for the adequacy and accuracy of the disclosures in the Amendment No. 1 on Form 10-K/A filed with the Commission on March 20, 2015 (the “Filing”); |
· | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the Filing; and |
· | 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. |
Sincerely,
Health Advance Inc.
By:/s/ Jordan Starkman
Name: Jordan Starkman
Title: Chief Executive Officer