LUNA TECHNOLOGIES INTERNATIONAL, INC.
61B Fawcett Road
Coquitlam, British Columbia
Canada V3K 6V2
July 13, 2006
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E
Washington, DC 20549
Attention: Edward M. Kelly, Senior Counsel
Christopher B. Edwards, Special Counsel
Pamela A. Long, Assistant Director
Re: Luna Technologies International, Inc.
Registration Statement on Form SB-2
File No. 333-133727
Ladies and Gentlemen:
Pursuant to Rule 461 of the General Rules and Regulations under the
Securities Act of 1933, as amended (the "Act"), Luna International Technologies
(the "Company") respectfully requests that the effective date of the
registration statement referred to above be accelerated so that it will become
effective at 11:00 a.m., Eastern Time, on Monday July 17, 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.
Very truly yours,
Luna Technologies International, Inc.
By: /s/ Kimberly Landry
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Kimberly Landry
Chief Executive Officer