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Mail Stop 3561          August 12, 2008  Ivo Heiden Chief Executive Officer Zaxis International Inc. 6399 Wilshire Boulevard, Suite 1019 Los Angeles, CA 90048

Re: Zaxis International Inc.
Form 10-KSB/A for Fiscal Year Ended  December 31, 2007 Filed August 4, 2008
 File No. 000-15746

Dear Ivo Heiden:
 We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise 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 deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.    Please understand that the purpose of our re view 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 ou r 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/A for Fiscal Year Ended December 31, 2007

 Item 8A. Controls and Procedures

 Evaluation of Disclosure Cont rols and Procedures, page 13

 1. We note that your amended Form 10-KSB pr ovides a partial definition of disclosure
controls and procedures.  Please revise you r disclosure to either remove the partial
definition, or to provide the entire definiti on.  If you include the entire definition in
your amended Form 10-KSB, your revised disclo sure should also stat e, if true, that

Ivo Heiden
Zaxis International Inc. August 12, 2008 Page 2

your disclosure controls and procedures include, without limitation, controls and
procedures designed to ensure that informa tion required to be disclosed in the reports
that you file or submit under the Exchange Act is accumulated and communicated to management to allow timely decision s regarding required disclosures.
 2. We note that in your amended Form 10-KS B your management has again concluded
your disclosure controls and procedures were ef fective as of the end of the fiscal year.
In our letter dated July 17, 2008, we asked you to consider whether management's
failure to provide its repor t on internal control over fi nancial reporting impacts its
conclusion regarding the effectiveness of your  disclosure controls  and procedures as
of the end of the fiscal year.  Please tell us the factors you cons idered and highlight
for us those factors that supported your c onclusion. Otherwise, please further amend
your Form 10-KSB to disclose management's  revised conclusion on the effectiveness
of your disclosure controls and procedures as of the end of the fiscal year and any
remediation plans that have  or will be enacted.
 As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response.  You may wish to
provide us with marked copies of the amendm ent 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 co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.
  We urge all persons who are responsibl e 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 invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

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

Ivo Heiden
Zaxis International Inc. August 12, 2008 Page 3

 You may contact Ethan Horowitz, Staff Accountant, at (202) 551-3311 or me at
(202) 551-3390 if you have questions regard ing comments on the financial statements
and related matters.
 Sincerely,    Brian K. Bhandari Branch Chief Office of Beverages, Apparel and  Health Care Services