Mail Stop 4561
      January 9, 2006

Mr. Paul T. Anthony
Chief Financial Officer
Auxilio, Inc.
27401 Los Altos, Suite 100
Mission Viejo, CA 92691

	Re:	Auxilio, Inc.
		Form 10-KSB for Fiscal Year Ended December 31, 2004
		Form 10-QSB for Quarterly Period Ended March 31, 2005
		Form 10-QSB for Quarterly Period Ended June 30, 2005
		File No. 0-27507

Dear Mr. Anthony:

      We have reviewed your response letter dated October 20, 2005
and have the following additional comments.  In our comments, we
ask
you to provide us with additional 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-KSB for the Fiscal Year Ended December 31, 2004

Item 8A Controls and Procedures, page 18

1. We have read your response to our previous comment one where
you
indicated that management believes the Company`s controls and
procedures were effective as of December 31, 2004.  We also note
in
your response that your independent registered public accounting
firm
advised you of a material weakness that involved unrecorded
transactions and disclosure deficiencies relating to SFAS No. 109.
In addition you state that you did not possess the technical
expertise required

to calculate a complex tax provision.  Please revise to disclose
how
management determined that the disclosure controls and procedures
were effective considering your disclosures noted above.

2. We note your proposed disclosure that "Except as discussed in
the
following paragraph...there have been no changes in internal
controls..."  You should state clearly, if correct, that there
were
changes in your internal control over financial reporting that
occurred during this quarter that have materially affected or are
reasonably likely to materially affect, your internal control over
financial reporting.

Note 2 - Acquisition, page F-14

3. We note in your response to our previous comment four that Mr.
Mayo as part of the severance agreement was to relinquish all of
his
equity instruments in the Company and this agreement was entered
into
prior to the completion of the acquisition accounting.  Please
tell
us how you accounted for the return of the equity instruments that
you previously issued for the Mayo Group and the accounting
literature you used to support your conclusion.

      Please respond to the comments included in this letter
within
ten business days.  If you have any questions, you may contact
Thomas
Flinn, Staff Accountant, at (202) 551-3469 or the undersigned at
(202) 551-3414 if you have questions.
      			Sincerely,


      Jorge Bonilla
      Senior Staff Accountant



Mr. Paul T. Anthony
Auxilio, Inc.
January 9, 2006
Page 1