SecProbe.io

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                               HAROLD W. PAUL, LLC
                                 ATTORNEY AT LAW
                                  PO Box 33812
                               Santa Fe, NM 87594
                                 (505) 983-2794
                               Fax (866) 644-7615

                                                         July 28, 2009

Jerard Gibson, Esq.
Securities and Exchange Commission
Mail Stop 4561
100 F Street, NE
Washington, DC 20549

                              Re: TOMI Environmental Solutions, Inc.
                                  Form 10-K for the year ended December 31, 2008
                                  File No. 0-09908

Dear Mr. Gibson:

     We represent TOMI Environmental Solutions, Inc.  Our client has forwarded
to us your letter dated June 23, 2009 and authorized us to reply.

Form 10-K for the year ended December 31, 2008
----------------------------------------------

Item 1.  Business
-----------------

General
-------

1.     Confirming our telephone conversation, we supplementally advise that we
do not believe it is material to expand the disclosure regarding the issuer's
intellectual property.  As disclosed in Form 10-K under the section entitled
Services, the issuer purchased a proprietary system for ozone generation from
two separate companies, which forms the core of its business and which the
issuer believes provides necessary protection.  This proprietary system is
not patented nor does the issuer believe that a patent would provide additional
protection or advance its interests.

<PAGE>

HAROLD W. PAUL, LLC

Jerard Gibson, Esq.
Securities and Exchange Commission
July 28, 2009
Page Two

Products, page 2
----------------

2.     Supplementally we advise that it is well settled scientifically that
ozone is a more powerful oxidizer and more quickly disinfects than chlorine.
Attached please find information underlying the foregoing.  The information
regarding expanding market for ozone technology is based upon research compiled
by Frost & Sullivan indicating an increase in demand for non-chemical
disinfection technologies such as ozone and ultraviolet light in a variety of
markets.

3.     Supplementally we advise that government regulation and cost of
compliance with environmental laws (Regulation S-K Item 101 (h)(4)(ix) and (xi))
are inapplicable as the regulation of ozone usage is related to occupied space.
The issuer, as disclosed in Form 10-K, applies ozone in greater levels than EPA
allowances; however, it does so in unoccupied and contained spaces.  The issuer
has disclosed that people, plants and pets must be removed from the premises
during treatment.

Competitors & Future Competition, page 6
----------------------------------------

4.     Supplementally we advise that the disclosure in the document referred to
direct public competition.    The market for air cleaning has a panoply of
different treatments, including many over the counter products, but to the
issuer's knowledge no public company is using similar ozone methodology.

Item 1A. Risk Factors
---------------------

General
-------

5.     We acknowledge the staff's comment and represent that these are the risks
the company deemed material at the time of this filing.  In future filings it
will delete any reference to other potential risks and uncertainties.

<PAGE>

HAROLD W. PAUL, LLC

Jerard Gibson, Esq.
Securities and Exchange Commission
July 28, 2009
Page Three

Item 5. Market for Registrant's Common Equity, Related Stockholder Matters and
------------------------------------------------------------------------------
Issuer Purchases of Equity Securities
-------------------------------------

Recent Sales of Unregistered Securities, page 10

6.     Confirming our telephone conversation, the information concerning the
exemption from registration was disclosed in a timely manner in Form 8-K at the
time of the transaction and was not repeated in this document.  The reason
language was included on the sale of securities previously disclosed was to
avoid any confusion with the disclosure made in the subsequent event footnote
to the financial statement.

Item 7. Management's Discussion and Analysis of Financial Condition and Results
-------------------------------------------------------------------------------
of Operations
-------------

Overview, page 11
-----------------

7.   We acknowledge the staff's comment and represent that a more complete
discussion of the business growth strategy and the lack of revenues will be made
in the issuer's next 10-Q.  At the time this Form 10-K was filed the issuer had
not generated any material revenue and was in the process of seeking additional
capital.  As disclosed, the issuer did raise capital in the first quarter and
began to profitably earn revenue in the second quarter and its current business
model assumes appropriate profit margins.

Item 8. Financial Statements and Supplementary Data
---------------------------------------------------

Financial Statements
--------------------

Note 4 - Intangible Assets, page F-12
-------------------------------------

8.     Supplementally we advise that the issuer believes that the amortization
number would have been immaterial-approximately $10,000 for the reporting
period, which is both qualitatively and quantitatively immaterial-and therefore,
did not disclose same in Form 10-K.  As discussed with the staff, the issuer
will begin to amortize those intangible assets in the second quarter of 2009
and this will be reflected in the upcoming 10-Q.

<PAGE>

HAROLD W. PAUL, LLC

Jerard Gibson, Esq.
Securities and Exchange Commission
July 28, 2009
Page Four

Item 9A. Controls and Procedures
--------------------------------

Disclosure Controls and Procedures, page 13
-------------------------------------------

9.     We note the staff's comment and represent that in future filings the
issuer will delete the qualifying language regarding assurance that the
disclosure controls will be effective.  The issuer believes that its disclosure
controls and procedures are designed to provide reasonable assurance of
achieving their objectives and that management believes that they are effective.

Item 11. Executive Compensation, page 15
----------------------------------------

10.    We acknowledge the staff's comment regarding a compensation table and
advise that inasmuch as only one person received compensation and that such
compensation consisted solely of salary the issuer believed that narrative
disclosure was sufficient.  We represent that in the future filings appropriate
disclosure will be made in tabular form as well.

As discussed more fully in the financial statement footnotes, Dr. Shane was
entitled to receive salary under his employment contract, a substantial portion
of which was unpaid and accrued since the company did not have sufficient funds
to pay him.  The company will continue to accrue his salary until such time it
has sufficient revenue and cash flow to pay him without impacting operations.
A copy of Dr. Shane's employment contract will be filed with the next 10-Q.

Exhibits
--------

11.    Supplementally we advise that the broker agreement discussed on page 5
was not deemed material requiring a filing as an exhibit as they have not
generated revenue to date.  With respect to the investment documents discussed
on page 11, we believed that the subscription agreement had been filed with the
above mentioned Form 8-K.  We will file that document with the next 10-Q.

<PAGE>

HAROLD W. PAUL, LLC

Jerard Gibson, Esq.
Securities and Exchange Commission
July 28, 2009
Page Five

Please advise if you have any further comment with regard to this filing or to
this response letter.

							Sincerely,

                                                    /s/ HAROLD W. PAUL, LLC

/sl							HAROLD W. PAUL, LLC

cc:  Halden Shane
     TOMI Environmental Solutions, Inc.

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