SecProbe.io

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Mail Stop 0610
      June 16, 2005

Mr. Dennis L. Bergquist
Chief Financial Officer
Molecular Diagnostics, Inc.
414 N. Orleans St., Suite 502
Chicago, IL 60610

      Re:	Molecular Diagnostics, Inc.
      Form 10-KSB for the year ended December 31, 2004
		File No. 000-00935

Dear Mr. Bergquist:

      We have reviewed your filing and have the following
comments.
We have limited our review to matters related to the issues raised
in
our comments.  Where indicated, we think you should revise your
document in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-KSB for the year ended December 31, 2004

Item 6 - Management`s Discussion and Analysis or Plan of
Operation,
page 26

Restructuring Settlements, page 30

1. We note that in 2004 you recognized a gain of $1,008,000
related
to restructuring settlements.  Please tell us and revise future
filings to:

* describe the nature of the significant components of the gain,
and
* explain why the presentation of the amount as non-operating
income
in your consolidated statements of operations is appropriate.

Additionally it appears as though you have presented this amount
on a
different line item in your 2003 income statements.  Please revise
future filings to ensure that all items are correctly and
consistently classified.

Liquidity and Capital Resources, page 31

2. We see that many of your notes payable are past due, including
Bridge I, Bridge II, Monsun and MonoGen.  Please revise future
filings to add a detailed discussion regarding the default
provisions
and debt covenants for each note and the possible impact on your
financial position, operations and liquidity.

Item 8A - Controls and Procedures, page 32

3. We note your statement that your chief executive officer and
your
chief financial officer "have concluded the Company`s current
disclosure controls and procedures, as designed and implemented,
are
reasonably adequate to ensure that such officers are provided with
information relating to the Company required to be disclosed in
the
reports the Company files or submits under the Exchange Act and
that
such information is recorded, processed, summarized and reported
within the specified time periods."  It does not appear that your
certifying officers have reached a conclusion that your disclosure
controls and procedures are effective.  Please revise future
filings
to address your officers` conclusions regarding the effectiveness
of
your disclosure controls and procedures.

Financial Statements, page F-1

Report of Independent Auditors, page F-2

4. We note that pursuant to Rule 2-05 of Regulation S-X your
filing
includes the audit opinion of Auditeurs & Conseils Associes as it
relates to your SARL Samba Technologies subsidiary.  Please have
Auditeurs & Conseils Associes revise their auditors` report to
comply
with AU Section 508: Reports on Audited Financial Statements and
Public Company Accounting Oversight Board (PCAOB) Auditing
Standard
No. 1 - References in Auditors` Reports to the Standards of the
Public Company Accounting Oversight Board.
5. Please revise to refer to your auditors by their full legal
name.
We assume that is the same name by which they are registered with
the
PCAOB.  Please similarly revise the audit report presented on page
F-
1.

Consolidated Statements of Operations, page F-4
6. Please revise future filings to include your litigation
settlement
expenses within your operating loss or tell us why your current
presentation is appropriate.

Note 13 - Legal Proceedings, page F-28

7. For each legal matter you have referenced tell us and revise
future filings to disclose the amount of any charges that you took
in
2003 and 2004.  Also tell us and disclose in future filings the
amount of any liabilities that you have recorded related to these
legal matters as of December 31, 2004.  Additionally, please
revise
your future disclosures to indicate your expectations as to the
likelihood of the legal contingencies having a negative material
impact on your income statement.  Note that if it is at least
reasonably possible that any contingency could have a material
negative impact on your financial statements, the notes to the
financial statements must either disclose the range of possible
loss
or indicate no such estimate can be made.  Refer to paragraph 10
of
Statement 5.

        As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed decision.  Since the company and
its management are in possession of all facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Eric Atallah, Staff Accountant at (202) 551-
3663
or me at (202) 551-3603 regarding comments on the financial
statements and related matters.  In this regard, do not hesitate
to
contact Angela Crane, Branch Chief, at (202) 551-3554.

      								Sincerely,

								Jay Webb
								Reviewing Accountant

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Mr. Dennis L. Bergquist
Molecular Diagnostics, Inc.
June 16, 2005
Page 4

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