November 29, 2006

Via Facsimile ((713) 877-1547) and U.S. Mail

Robert L. Sonfield, Jr., Esq.
Managing Director
Sonfield & Sonfield
770 South Post Oak Lane, Suite 435
Houston, TX 77056

Re:	MediQuip Holdings, Inc.
	Schedule 14F-1 filed November 24, 2006
	File No. 005-79086

Dear Mr. Sonfield:

	We have reviewed the Schedule 14F-1 referenced above and have
the following comment.
1. We note you have provided some of the disclosure by Item 6(d)
of
Schedule 14A.  Please revise your schedule to provide all of the
information required by Items 6(a), (d) and (e), 7 and 8 of
Schedule
14A.  Refer to Rule 14f-1.  In addition, given the substantial
lack
of compliant disclosure, please tell us whether you intend to
recirculate your information statement.

Closing Comments

	Please revise your Schedule 14F-1 to comply with the comments
above.  If you do not agree with a comment, tell us why in a
supplemental response letter that you should file via EDGAR as
correspondence.  The letter should note the location in your
amended
disclosure document of changes made in response to each comment or
otherwise.

	Note that we may have additional comments after we review
your
amendment and response letter.  Please indicate how you intend to
disseminate the amended Schedule 14F-1 filed in response to the
comments above.

	In connection with responding to our comments, please provide
a
written 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 in the filings reviewed by the staff 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.

	Please contact the undersigned at (202) 551-3619 with any
questions.

						Sincerely,



						Daniel F. Duchovny
						Special Counsel
						Office of Mergers and Acquisitions
Robert L. Sonfield, Jr., Esq.
Sonfield & Sonfield
November 29, 2006
Page 1



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

         DIVISION OF
CORPORATION FINANCE