January 11, 2004


B. Steven Springrose
President and Chief Executive Officer
Biotel Inc.
11481 Rupp Drive
Burnsville, Minnesota 55337

Re:	Biotel Inc.
      Amendment 2 to Registration Statement on Form 10-SB
      Filed December 27, 2004
		File No. 0-50914

Dear Mr. Springrose:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-SB

Part F/S

Notes to Consolidated Financial Statements - Page F-21

Note 16 - Asset Purchase - Page F-32
1. We note disclosures herein that for the quarter ending
September
30, 2004, Agility Centralized Research Services, LLC (Agility),
had
revenues of $11,000, expenses of $135,000 and a net loss of
$124,000.
We also see your fiscal 2004 pre tax net income was $1,048,346.
Please supplementally provide us with the calculations outlined at
Item 310(c)(2)(iii) Regulation S-B for the Agility acquisition.
Revise the filing to include any Agility historical financial
statements required by Item 310 (c) of Regulation S-B.

*   *   *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.









      You may contact Eric Atallah at (202) 824-5266 or Jay Webb
at
(202) 942-1812 if you have questions regarding comments on the
financial statements and related matters. Please contact Adelaja
Heyliger at (202) 824-5082 or me at (202) 942-1927 with any other
questions.

Sincerely,



							Thomas A. Jones
      Senior Attorney

cc (via fax):	Rick Hauser, Esq.  Gray, Plant, Mooty, Mooty &
Bennett, P.A.  612.632.4095
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Biotel Inc.
January 11, 2004
Page 1