EXHIBIT  32


      STATEMENT REQUIRED BY 18 U.S.C. SECTION 1350, AS ADOPTED PURSUANT TO
                  SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002

In connection with the Quarterly Report on Form 10-QSB of HairMax International,
Inc. (the "Company") for the nine months ended September 30, 2004, as filed with
the  Securities  and  Exchange  Commission on the date hereof (the "Report"), I,
Edward  A.  Roth,  Chief  Executive  Officer,  and Michael J. Bongiovanni, Chief
Financial  Officer  of  the  Company,  certify  that:

*    the  Report  fully complies with the requirements of Section 13(a) or 15(d)
     of  the  Securities  Exchange  Act  of  1934;  and

*    information  contained  in  the  Report  fairly  presents,  in all material
     respects,  the financial condition and results of operations of the Company
     on  the  dates  and  for  the  periods  presented.


/s/  Edward  A.  Roth
- ---------------------
Edward  A.  Roth
Director,  President  and  Chief  Executive  Officer

November  11,  2004


/s/  Michael  J.  Bongiovanni
- -----------------------------
Michael  J.  Bongiovanni
Director  and  Chief  Financial  Officer

November  11,  2004


This  certification  accompanies  this  Report  pursuant  to  Section 906 of the
Sarbanes-Oxley  Act  of 2002 and shall not, except to the extent required by the
Sarbanes-Oxley  Act  of  2002,  be  deemed  filed by the Company for purposes of
Section  18  of  the  Securities  Exchange  Act  of  1934,  as  amended.