December 21, 2005



Mr. William E. Prince
Chief Executive Officer and Principal Financial Officer
Integrated Environmental Technologies, Ltd.
4235 Commerce Street
Little River, South Carolina  29566


	Re:	Integrated Environmental Technologies, Ltd.
		Form 10-KSB for Fiscal Year Ended December 31, 2004, as
amended
Filed March 30, 2005 and December 9, 2005
		Forms 10-QSB for Fiscal Quarters
      Ended March 31, 2005, June 30, 2005 (as amended)
      and September 30, 2005
      Filed May 17, 2005, August 19, 2005, December 9, 2005
      and November 14, 2005
      Response Letters Dated October 11, 2005 and December 7, 2005
		File No. 0-26309

		Form SB-2
		Filed October 3, 2005
		File No. 333-128759


Dear Mr. William E. Prince:

      We have reviewed your filings and response letters and have
the
following comments.  We have limited our review of your filing to
those issues we have addressed in our 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 information so we may better
understand your disclosure.  After reviewing this information, we
may
raise additional comments.


Form SB-2, filed October 3, 2005

General

1. Please update the interim financial statements and the related
management`s discussion and analysis discussion as needed.  Refer
to
Item 310(g) of Regulation S-B.

2. Please update your independent auditors` consent.

Closing Comments

      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 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 to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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.

      We will consider a written request for acceleration of the
effective date of the registration statement as confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Regina Balderas at (202) 551-3722 or Jill
Davis, Branch Chief, at (202) 551-3683 if you have questions
regarding comments on the financial statements and related
matters.
Please contact Tangela Richter at (202) 551-3685 with any other
questions.  Direct all correspondence to the following ZIP code:
20549-7010.

								Sincerely,



								Jill S. Davis
								Branch Chief

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Mr. William E. Prince
Integrated Environmental Technologies, Ltd.
December 21, 2005
page 3



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010