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UNIVERSAL DETECTION TECHNOLOGY
9595 WILSHIRE BLVD., SUITE 700
BEVERLY HILLS, CA 90212
TEL: 310-248-3655
FAX: 310-273-2662
August 20, 2008
FILED AS CORRESPONDENCE VIA EDGAR
Securities and Exchange Commission
100 F. Street N.E.
Washington, DC 20549
Mail Stop 6010
Attn: Mr. Kevin L. Vaughn
Mr. David Burton
RE: UNIVERSAL DETECTION TECHNOLOGY
FORM 10-KSB FOR THE YEAR ENDED DECEMBER 31, 2007
FILED APRIL 14, 2008
FORM 10-Q/A FOR THE QUARTER ENDED MARCH 31, 2008
FILED MAY 20, 2008
FILE NO. 1-09327
Dear Mr. Vaughn and Mr. Burton:
On July 19, 2008, we submitted a letter to the Securities and Exchange
Commission (the "SEC") and Universal Detection Technology's (the "Company")
Amendment No. 1 to Form 10-KSB for the fiscal year ended December 31, 2007 (the
"Amended Annual Report") and Amendment No. 2 to Form 10-Q for the quarter ended
March 31, 2008 (the "Amended Quarterly Report"). The Amended Annual Report and
the Amended Quarterly Report contain revisions that were made in response to the
comments received from the staff ("Staff") of the SEC on May 6, 2008. In
connection with responding to Staff comments the Company failed to provide a
written acknowledgment as requested by the Staff in the May 6, 2008 letter.
Accordingly, please find attached the Company Certification and Acknowledgment
as requested in your May 6, 2008 letter.
We hope that the acknowledgment attached to this letter satisfactorily
addresses the comments and requests by the Staff. Should you have any further
questions regarding the above, please contact the undersigned at 310-248-3655 or
by fax at 310-273-2662.
Very truly yours,
UNIVERSAL DETECTION TECHNOLOGY
By: /S/ MR. JACQUES TIZABI
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Jacques Tizabi
Chief Executive Officer
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Securities and Exchange Commission
Re: Universal Detection Technology
August 20, 2008
Page 2
COMPANY CERTIFICATION AND ACKNOWLEDGMENT
On behalf of Universal Detection Technology (the "Company), I, Jacques
Tizabi, certify and acknowledge as follows in connection with responding to the
Staff's comment letter dated May 6, 2008:
1. I am the duly appointed Chief Executive Officer of the Company and
have the power and authority to make the certification and
acknowledgment contained herein for the Company;
2. the Company is responsible for the adequacy and accuracy of the
disclosure in the Company's filings with the Commission;
3. Staff comments or changes to disclosure in response to Staff comments
do not foreclose the Commission from taking any action with respect to
the Company's filings with the Commission; and
4. 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.
/s/ Jacques Tizabi
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Jacques Tizabi
Chief Executive Officer
Universal Detection Technology
Phone: (310) 248-3655
Fax: (310) 273-2662
Email: INFO@UDETECTION.COM