Law Office of
Christopher Olander & Associates LLC
Attorney At Law | 12407 Garrison Forest Road | |
Management Consulting | Owings Mills, Maryland 21117 | |
410-363-3274 (office) | ||
309-406-1207 (fax) | ||
443-854-3040 (cell) |
July 17, 2007
Via EDGAR and Federal Express
Mark P. Shuman
Branch Chief
and
Jay Ingram
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Avatech Solutions, Inc. |
Registration Statement on Form S-1
Filed on February 2, 2007
Commission File No. 333-140418
Gentlemen:
Filed contemporaneously herewith, via EDGAR, is Amendment No. 2 (the “Amendment”) to the Registration Statement on Form S-1 (the “Registration Statement”) of Avatech Solutions, Inc. (the “Company”). We have also sent to Mr. Ingram, by overnight delivery service, a copy of this letter and a copy of the Amendment marked to show changes to the Registration Statement effectuated by the Amendment.
The following indicates the changes made to the Registration Statement in response to your comments communicated by telephone to the undersigned on June 21, 2007:
We have added to Item 17 (Undertakings) of Part II as set forth in Item 512(a)(5)(ii) of Regulation S-K.
Assuming no further comments are deemed necessary by the Commission’s staff, the Company will request that effectiveness of the Registration Statement be accelerated. At that time, Lawrence Rychlak, Executive Vice President and Chief Financial Officer of the Company, will make an acceleration request and provide the acknowledgments set forth in the Commission’s original comment letter.
Please do not hesitate to contact the undersigned if you have any questions or desire any additional information.
Sincerely, |
/s/ Christopher Olander |
Christopher Olander |