December 13, 2007



VIA EDGAR AND FEDERAL EXPRESS

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-3628
Attn: Pamela A. Long


         Re:      Water Chef, Inc.
                  Registration Statement on Form SB-2
                  File No.: 333-122252
                  Filed: October 16, 2007
                  Quarterly Report on Form 10-QSB for the period ended
                  June 30, 2007
                  Filed August 14, 2007


Dear Ms. Long:

     Following the above-referenced matter and the phone conversation we had
with Mr. Craig Slivka of your office, the following is a supplement to our
response dated December 5, 2007, on behalf of Water Chef, Inc. (the "Company").

1.   The Company's auditors, Marcum & Kliegman, LLP, were the ones who
     identified the weaknesses, in December 2006, during the preparations of the
     2006 10-KSB, while the Company was in a transition stage (the former Chief
     Executive Officer and Chief Financial Officer resigned; the company hired a
     Chief Executive Officer and a Chief Financial Officer, and a Controller).

2.   The significant weakness was the lack of segregation of duties at the
     Company due to the small number of employees dealing with general
     administrative and financial matters. This constituted a significant
     deficiency in the financial reporting of the Company, specifically relating
     to accounting for debt and equity based transactions.

     As noted in Section 1 above, the material weakness was detected by the
     Company's auditors and during the filings of the second quarter 10-QSB
     several positive changes have taken place in this regard:




     a.   On October 1, 2007, Kris Dillmann was hired as controller/bookkeeper.
          Ms. Dillmann has an MS in accounting and was a controller of a law
          firm for 9 years prior to joining the Company.

     b.   On October 1, 2007, Terry Lazar was hired as the Company's Chief
          Financial Officer. Mr. Lazar is a Certified Public Accountant and has
          been a Partner in a CPA firm for many years.

     c.   The Resnick Druckman Group LLC reviews monthly reporting of all
          financial transactions and, more specifically, all financial debt
          transactions of the Company.

     The system for eliminating the reported deficiencies includes both a
     segregation of duties and multiple reviewers of financial transactions and
     financial reporting, with particular attention to debt financing
     transactions. Ms. Dillmann's functions are reviewed by Mr. Lazar on a
     regular basis. Monthly, all reporting and any debt and equity transactions
     and black shole computations are reviewed by Mr. Lazar, as well as by The
     Resnick Druckman Group LLC.

                                    * * * * *

     The Company acknowledges that it is responsible for the adequacy and
accuracy of the disclosure in the filing; 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 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.

     Please direct any questions or comments concerning this response to Yael
Harari at (212) 451-2224 or to the undersigned at (212) 451-2252.

                                            Very truly yours,



                                            /s/  Kenneth A. Schlesinger
                                            -----------------------------------
                                                 Kenneth A. Schlesinger

cc:      Leslie J. Kessler
         Terry Lazar