Addison-Davis Diagnostics, Inc.
143 Triunfo Canyon Road, Suite 104
Westlake Village, CA 91361
July 10, 2006
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Attention: Jeffrey P. Riedler, Assistant Director
Gregory S. Belliston, Staff Attorney
Re: Addison-Davis Diagnostics, Inc.
Amendment No. 1 to Registration Statement on Form SB-2
Filed June 28, 2006 (File No. 333-134667)
Ladies and Gentlemen:
Pursuant to Rule 461 of the General Rules and Regulations under the
Securities Act of 1933, as amended (the "Act"), Addison-Davis Diagnostics, Inc.
(the "Company") respectfully requests that the effective date of the
registration statement referred to above be accelerated so that it will become
effective at 4:00 p.m., Eastern Time, on Tuesday, July 11, 2006, or as soon
thereafter as possible.
We hereby acknowledge the following:
o that should the Commission or the staff, acting pursuant to
delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the
filing;
o the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the Company from its full responsibility for the adequacy
and accuracy of the disclosure in the filing; and
o the Company may not assert staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.
Addison-Davis Diagnostics, Inc.
By: /s/ Charles Miseroy
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Name: Charles Miseroy
Title: President