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SEC Company Response from Viewbix Inc. (VBIX) (CIK 0000797542) (QXL) — Aug 4, 2008

Viewbix Inc. (VBIX) (CIK 0000797542)
Date: Aug. 4, 2008 · CIK: 0000797542 · Accession: 0001295345-08-000067

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File numbers found in text: 000-15746

Referenced dates: July 17, 2008

Date
August 4, 2008
Author
/s/ Ivo Heiden
Form
CORRESP
Company
Viewbix Inc. (VBIX) (CIK 0000797542)

Letter

United States Securities and Exchange Commission Division of Corporation Finance Attention: Ethan Horowitz, Staff Accountant Re: Zaxis International Inc. Form 10-KSB for the Fiscal Year Ended December 31, 2007 Commission File No. 000-15746

Dear Mr. Horowitz:

This letter is in response to the staff’s comment letter dated July 17, 2008 regarding the above-referenced filing. Please note that we have filed the Form 10-KSB/A and have included revised disclosure under Item 8A to address the staff’s comment letter.

In addition, on behalf of Zaxis International Inc. (the “Company”), I acknowledge that:

Ÿ The Company is responsible for the adequacy and accuracy of the disclosure in the subject filing;

Ÿ Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the subject filing; and

Ÿ 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.

Sincerely,
/s/ Ivo Heiden

Show Raw Text
CORRESP
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ZXSI

Zaxis International Inc.

6399 Wilshire Blvd, Suite 1019

Los Angeles, CA 90048

Phone: (323) 951-0575 - FAX: (212) 658-9867

August 4, 2008

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N. E.

Washington, DC 20549

Mail Stop: 3561

Attention: Ethan Horowitz, Staff Accountant

Re: Zaxis International Inc.

Form 10-KSB for the Fiscal Year Ended December 31, 2007

Commission File No. 000-15746

Dear Mr. Horowitz:

This letter is in response to the staff’s comment letter dated July 17, 2008
regarding the above-referenced filing. Please note that we have filed the Form 10-KSB/A
and have included revised disclosure under Item 8A to address the staff’s comment
letter.

In addition, on behalf of Zaxis International Inc. (the “Company”), I
acknowledge that:

Ÿ The Company is responsible for the adequacy
and accuracy of the disclosure in the subject filing;

Ÿ Staff comments or changes to disclosure in
response to staff comments do not foreclose the Commission from taking any action with
respect to the subject filing; and

Ÿ 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.

Sincerely,

/s/ Ivo Heiden

Ivo Heiden, CEO/CFO