January 25, 2008


Securities and Exchange Commission, Mail Stop 6010
100 F Street N.E.
Washington, DC 20549
Attn: Julie Sherman, Staff Accountant

         In re: Revolutions Medical Corporation
                    Commission File # 000-28629

Gentlemen:

This letter is in response to Item #4 in your comment letter of January 11,
2008.

In light of the amendment of the interim, unaudited financial statements for the
quarters ended March 31, 2007 and June 30, 2007, the certifying officer has
reviewed the disclosure controls and procedures as of the end of the periods.
The Company's disclosure controls and procedures are designed to ensure (i) that
information required to be disclosed by the Company in the reports the Company
files or submits under the Exchange Act are recorded, processed, summarized, and
reported within the time periods specified in the SEC's rules and forms; and
(ii) that information required to be disclosed by the Company in the reports it
files or submits under the Exchange Act is accumulated and communicated to the
Company's management, including its principal executive and principal financial
officer, or persons performing similar functions, as appropriate to allow timely
decisions regarding required disclosure.

The certifying officer recognizes that there were and are deficiencies that
existed, and continue to exist, in the design and operation of the Company's
internal controls over financial reporting which can be considered to be
"significant deficiencies". Because of the extremely limited size of the
management team and the lack of supporting staff, there was, and continues to
be, a lack of accounting personnel with the requisite knowledge of Generally
Accepted Accounting Principles in the US ("GAAP") and the financial reporting
requirements of the Securities and Exchange Commission. As of the end of both
quarters, and continuing, there were and are insufficient written policies and
procedures to insure the correct application of accounting and financial
reporting with respect to the requirements of GAAP and SEC disclosure
requirements. Furthermore, there has been, and continues to be, a lack of
segregation of duties, in that the Company has had only one person performing
all financial functions and only one other, non-employee person, performing the
accounting-related duties.



Notwithstanding the existence of these significant deficiencies in our internal
control over financial reporting, our management, including our Chief Executive
Officer and Chief Financial Officer, believes that the consolidated financial
statements included in the reports fairly presented in all material respects the
Company's financial condition, results of operations and cash flows for the
periods presented. The reason for the amendment of the interim financial reports
was due to a later decision that the technology acquired did not have viable
alternative uses, although it had originally been thought that it might have,
and had it been determined that there were viable alternative uses the interim
financial reports would have been correct.

The Company is considering how, given its limited working capital and inability
to utilize and support employees with the requisite financial and accounting
education and experience, it can address the weaknesses. The Company will
continue to evaluate the effectiveness of internal controls and procedures on an
on-going basis.

In connection with the foregoing response to your comment, the Company
acknowledges that: 1. The Company is responsible for the adequacy and accuracy
of the disclosure in the filings; 2. 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 3. 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.

Yours truly,
REVOLUTIONS MEDICAL CORPORATION

/s/ Rondald Wheet

By: Rondald Wheet, Pres/CEO