SecProbe.io

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Mail Stop 3561

June 23, 2005

Magnus Gittins
Advance Nanotech, Inc.
600 Lexington Avenue, 29th Floor
New York, New York 10022

	RE:  	Advance Nanotech, Inc.
		Registration Statement on Form SB-2
		File No. 333-125428
		Filed June 2, 2005

Dear Mr. Gittins:

      We limited our review of your filing to matters relating to
compliance with comments issued in connection with our review of
your
Form 10-KSB for fiscal year ended December 31, 2004 and Form 10-
QSB
for quarter ended March 31, 2005.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain 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 the event the company requests acceleration of the
effective
date of the pending registration statement, it should furnish a
letter, at the time of such request, acknowledging 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;

* 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

* 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.

	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 connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

	If you have any questions, please call Ted Yu at (202) 551-
3372
or me at (202) 551-3833.

Sincerely,

      Michele M. Anderson
Legal Branch Chief

cc:	L. Stephen Albright, Esq.  (via fax)
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Magnus Gittins
Advance Nanotech, Inc.
June 23, 2005
Page 2

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