================================================================================ 3/14/08 Kevin L. Vaughn Branch Cief United States Securities and Exchange Commission Division of Corporation Finance Washington, DC 20549 RE: Sparta Surgical Corporation Your Letter of February 14, 2008 Dear Mr. Vaughn, In response to your comment letter dated February 14, 2008, we respond as follows: Comment#1. We have made the change and replaced the word "adequate" with "effective". Comment#2. As you discussed with our counselor, we have revised the disclosure regarding the Consent of the Opinion Letter, the paragraph now reads as "Management beliefs, etc." Comment#3. We have made the change and eliminated "within 90 days of the filing date of this report" and disclosed the controls and procedures "as of the end of the period covered by the report." Comment#4. We have made the change and dated Form 10-KSB/A and Forms 10QBS/A to include current date certifications. Comment#5. We have made the change on Exhibit 31.1and furnished the proper form as currently set forth in Item 601(b) (31) of Regulation S-B. Exhibit 3.1 Sincerely, Sparta Surgical Corporation By: /s/ Allan J. Korn Chief Executive Officer and Chief Financial Officer - --------------------------------------------------------------------------------