SecProbe.io

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Mail Stop 6010
June 29, 2005

Via U.S. Mail and Facsimile

Ms. Barbara Woody
Controller and Principal Accounting Officer
American Medical Technologies, Inc.
5655 Bear Lane
Corpus Christi, TX 78405

      Re:	American Medical Technologies, Inc.
Form 10-KSB for Fiscal Year Ended December 31, 2004
Filed March 31, 2005
Form 10-QSB for Fiscal Quarter Ended March 31, 2005
File No. 000-19195

Dear Ms. Woody:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Where indicated, we think you should
revise your document in future filings 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 Fiscal Year Ended December 31, 2004

Item 6. Management`s Discussion and Analysis or Plan of
Operations,
page 9

Critical Accounting Policies, page 9

Inventories - Slow Moving, page 10

1. We note your disclosure that the "valuation allowance could
change
materially, either up or down, if actual part usage in future
years
is materially different than the usage projected."  In future
filings
please clarify that any inventory write-downs create a new cost
basis
that subsequently cannot be marked up based on changes in
underlying
facts and circumstances in accordance with SAB Topic 5.BB.

Results of Operations, page 10

2. In future filings, please quantify, in dollars, the reasons
that
you describe are primarily attributable to a change in a line
item.
For example, you say that gross profit improved because of the
elimination of the need to increase inventory reserves and an
increase in selling prices.  Also, in your March 31, 2005 Form 10-
QSB
you state that the improvement in gross profit is mostly
attributable
to decreases in the warranty provision and labor/overhead variance
and increased sales prices.  However, you do not list the dollar
impact of these changes.  In addition, each of the factors that
contributed to the improved margins and any significant changes in
expense amounts each period should be quantified and discussed, to
the extent practicable, along with details of whether these are
trends that are expected to continue.

Liquidity and Capital Resources, page 11

3. We see that cash used in operating activities has varied
significantly from period to period and that movements have been
inconsistent with earnings.  In future filings please provide a
more
detailed analysis of movements in operating cash flows from period
to
period.  That analysis should identify, describe and quantify the
underlying drivers of operating cash flows and should more fully
reflect the guidance from FR-72.  Please apply in future filings.

Item 7. Financial Statements, page 12

Consolidated Statements of Cash Flows, page 16

4. We note that the effect of exchange rates on cash of $11,542
and
$56,681 for 2004 and 2003, respectively, are the same as the
foreign
currency translations on your consolidated statements of
stockholders` equity.  Please tell us whether you prepared the
statement of cash flows for your German operations using the
exchange
rates in effect at the time of the cash flows in accordance with
paragraph 25 of SFAS 95.  Revise as necessary in future filings.

Note 1. Organization and Significant Accounting Policies, page 17

Inventories, page 18

5. We note that you that you record a 100% valuation allowance on
any
parts on hand exceeding three years of projected usage.  Please
tell
us whether you record any provision on parts that do not exceed
three
years, and how your accounting policy is in accordance with GAAP.
Refer to Chapter 4 of ARB 43.

Revenue Recognition, page 19

6. We note from your website that you grant your customers a money
back guarantee, whereby "all items except otherwise mentioned, may
be
returned within 30 days from the original invoice date."  In
future
filings your revenue recognition policies should address the
extent
of any rights of return in accordance with SFAS 48.

Receivables and Credit Policies, page 19

7. We note that your valuation allowance includes a provision for
5%
of the balance less than 90 days past due.  Please tell us how you
determined the 5% provision rate, whether it is a general reserve,
and how it is in accordance with GAAP, citing applicable
literature.

Intangible Assets, page 19

8. We note that the Company recorded a goodwill impairment of
$1,971,427 in the fourth quarter of 2003.  Please tell us why the
goodwill was not tested for impairment during the second quarter
of
2003 when you sold the dental laser assets to Biolase Technologies
in
accordance with paragraph 28 of SFAS 142.

9. Additionally, please tell us why the goodwill was not allocated
to
the dental laser assets sold to Biolase Technologies and included
in
the calculation of the gain on the sale.

Note 3. Sale of Dental Laser Assets, page 22

10. Please tell us why the sale of the dental laser assets to
Biolase
Technologies on May 21, 2003 was not accounted for as a
discontinued
operation in accordance with SFAS 144.

Form 10-QSB for the Quarterly Period Ended March 31, 2005

Condensed Consolidated Statements of Operations, page 2

11. We note from your statement of operations that there were no
dividends on the preferred stock for the first quarter of 2005.
However, your condensed consolidated statement of cash flows shows
a
cash payment of $40,000 for Series B preferred dividends.  Please
reconcile the two statements and revise future filings as
necessary.

       As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  When sending supplemental
information regarding this filing, please include the following
ZIP+4
code in our address: 20549-6010.  Please understand that we may
have
additional comments after reviewing your 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 Lynn Dicker at (202) 551-3616 or me at (202)
551-3605 if you have questions regarding comments on the financial
statements and related matters.  In this regard, do not hesitate
to
contact Martin James, Senior Assistant Chief Accountant, at (202)
551-3671.

Sincerely,

Brian Cascio
Accounting Branch Chief

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Ms. Barbara Woody
American Medical Technologies, Inc.
June 29, 2005
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