Zaxis International Inc.
6399 Wilshire Blvd, Suite 1019
Los Angeles, CA 90048
Phone: (323) 951-0575 - FAX: (212) 658-9867
August 4, 2008
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N. E.
Washington, DC 20549
Mail Stop: 3561
Attention: Ethan Horowitz, Staff Accountant
Re: Zaxis International Inc.
Form 10-KSB for the Fiscal Year Ended December 31, 2007
Commission File No. 000-15746
Dear Mr. Horowitz:
This letter is in response to the staff’s comment letter dated July 17, 2008 regarding the above-referenced filing. Please note that we have filed the Form 10-KSB/A and have included revised disclosure under Item 8A to address the staff’s comment letter.
In addition, on behalf of Zaxis International Inc. (the “Company”), I acknowledge that:
Ÿ The Company is responsible for the adequacy and accuracy of the disclosure in the subject filing;
Ÿ Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the subject filing; and
Ÿ 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,
/s/ Ivo Heiden
Ivo Heiden, CEO/CFO
