October 10, 2005

VIA FACSIMILE (202) 772-9209

Owen Pinkerton, Senior Counsel
SECURITIES AND EXCHANGE COMMISSION
450 5th Street, N.W.
Washington DC 20549

MAIL STOP 4561


RE: Advanced 3-D Ultrasound Services, Inc.
Preliminary Proxy Materials on Schedule 14A
Registration No. 0-25097
Filed on September 27, 2005


Dear Mr. Pinkerton:

This firm represents Advanced 3-D Ultrasound Services, Inc. (the "Company"
or "Registrant") with regard to the above-referenced Preliminary Proxy
Materials. The letter of October 7, 2005 (the "Letter") received by the Company
from the staff of the Securities and Exchange Commission (the "Staff"), has been
forwarded to me for response to the comments contained therein. Please accept
this letter as the Company's response to the Staff's comments set forth in the
Letter. We also are enclosing revised Preliminary Proxy Materials that are
marked to show changes in response to the Staff's comments.

1. Please revise to include disclosure with respect to audit fees as required
by Item 9(e) of Schedule 14A.

In response to Comment No. 1 of the Letter, the section of the Proxy
labeled "Proposal 5: Approval of the Company's Auditors for the Year
Ending December 31, 2005" has been amended to include disclosure with
respect to the audit fees for the Company's auditors as required by
Item 9(e) of Schedule 14 A.

2. Please revise both your Ownership of Securities Table and your Summary
Compensation Table for clarity.

In response to Comment No. 2 of the Letter, please be advised that the
Ownership of Securities Table and Summary Compensation Table have been
revised to clarify the fact that the Executive Officers of the Company
were changed on June 29, 2005. The revision identifies only two of the
current officers in accordance with Item 402. Additionally, the
Ownership of Securities Table has been revised to include Rachel
Steele in the computation of All Officers and Directors as a group, in
accordance with Item 402(a(2).

Please be supplementally advised that the Registrant acknowledges the
following:

1. The adequacy and accuracy of the disclosure in the filing is the
responsibility of the Registrant.

2. The Registrant acknowledges that staff comment or changes in response
to the staff comment in the proposed disclosure in the preliminary
proxy materials do not foreclose the Commission from taking any action
with respect to the filing.

3. The Registrant also represents that staff comment may not be asserted
as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

We trust the above information adequately responds to the Staff's comments
raised in the Letter. Please contact me should you have any further comments or
questions.

Sincerely,

KIEFNER & HUNT, P.A.


Clifford J. Hunt, Esquire

Copies to: Benjamin C. Croxton, CEO
Advanced 3-D Ultrasound Services, Inc.

Paul Fisher, Esquire
Securities and Exchange Commission