October 10, 2005

VIA FACSIMILE (202) 772-9209

Owen  Pinkerton,  Senior  Counsel
SECURITIES  AND EXCHANGE  COMMISSION
450 5th Street, N.W.
Washington DC 20549

MAIL STOP 4561


         RE:      Advanced 3-D Ultrasound Services, Inc.
                  Preliminary Proxy Materials on Schedule 14A
                  Registration No. 0-25097
                  Filed on September 27, 2005


Dear Mr. Pinkerton:

     This firm represents Advanced 3-D Ultrasound Services,  Inc. (the "Company"
or  "Registrant")  with  regard  to  the   above-referenced   Preliminary  Proxy
Materials.  The letter of October 7, 2005 (the "Letter") received by the Company
from the staff of the Securities and Exchange Commission (the "Staff"), has been
forwarded to me for response to the comments  contained  therein.  Please accept
this letter as the Company's  response to the Staff's  comments set forth in the
Letter.  We also are enclosing  revised  Preliminary  Proxy  Materials  that are
marked to show changes in response to the Staff's comments.

1.   Please revise to include  disclosure with respect to audit fees as required
     by Item 9(e) of Schedule 14A.

          In response  to Comment No. 1 of the Letter,  the section of the Proxy
          labeled  "Proposal 5: Approval of the Company's  Auditors for the Year
          Ending December 31, 2005" has been amended to include  disclosure with
          respect to the audit fees for the  Company's  auditors  as required by
          Item 9(e) of Schedule 14 A.

2.   Please  revise both your  Ownership  of  Securities  Table and your Summary
     Compensation Table for clarity.

          In response to Comment No. 2 of the Letter, please be advised that the
          Ownership of Securities Table and Summary Compensation Table have been
          revised to clarify the fact that the Executive Officers of the Company
          were changed on June 29, 2005. The revision identifies only two of the
          current  officers  in  accordance  with  Item 402.  Additionally,  the
          Ownership  of  Securities  Table has been  revised to  include  Rachel
          Steele in the computation of All Officers and Directors as a group, in
          accordance with Item 402(a(2).

     Please be  supplementally  advised  that the  Registrant  acknowledges  the
following:

     1.   The  adequacy  and  accuracy  of the  disclosure  in the filing is the
          responsibility of the Registrant.

     2.   The Registrant  acknowledges that staff comment or changes in response
          to the staff  comment in the proposed  disclosure  in the  preliminary
          proxy materials do not foreclose the Commission from taking any action
          with respect to the filing.

     3.   The Registrant  also represents that staff comment may not be asserted
          as a defense in any  proceeding  initiated  by the  Commission  or any
          person under the federal securities laws of the United States.

     We trust the above information  adequately responds to the Staff's comments
raised in the Letter.  Please contact me should you have any further comments or
questions.

                                   Sincerely,

                                   KIEFNER & HUNT, P.A.


                                   Clifford J. Hunt, Esquire

Copies to:        Benjamin C. Croxton, CEO
                  Advanced 3-D Ultrasound Services, Inc.

                  Paul Fisher, Esquire
                  Securities and Exchange Commission