SecProbe.io

Mail Stop 3561
  November 29, 2006

Lance Jon Kimmel, Esq.
SEC Law Firm
11693 San Vicente Boulevard, Suite 357
Los Angeles, CA 90049

Re: NuWay Medical, Inc.
 Preliminary Proxy Statement on Schedule 14A
 Filed November 3, 2006
  File No. 0-19709

Dear Mr. Kimmel:

We have limited our review of your filing to those issues we have addressed in
our comments.  Where indicated, we think you should revise your document in response
to these comments.  If you disagree, we w ill consider your explanation as to why our
comment is inapplicable or a revision is unneces sary.  Please be as detailed as necessary
in your explanation.  In some of our comme nts, 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 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 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.

General
1. Please comply with any outstanding comment s that were issued as part of our
review of your Form 10-KSB for fiscal  year ended December 31, 2005 and Forms
10-QSB for fiscal quarters ende d March 31, 2006 and June 30, 2006.

Proposal 2, page 14
2. We note that you are seeking the approval for the acquisition of substantially all
of the assets of IOWC Technologies, Inc. and the issuance of 553,475,300 shares
of your common stock to consummate the acquisition.  Further, it appears that
you are also seeking approval to increase  the number of authorized common stock
from 100,000,000 shares to 200,000,000 shares and to effect a reverse stock split

Lance Jon Kimmel, Esq.
SEC Law Firm
November 29, 2006 Page 2
to facilitate the acquisition.  Accordin gly, it would appear that Items 11, 13 and
14 of Schedule 14A are applicable.  In th is regard, we note th at although you state
your intention to mail your annual and quart erly reports with the proxy statement,
your financial statements have not been included in or incorporated by reference
into the proxy statement.  Further, it al so appears that you have not included pro
forma financial information.  Please revise  to ensure that you have fully addressed
the disclosure requirements of Items 11, 13 and 14 of Schedule 14A or advise.  We may have further comment upon review of your response.

* * *

 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 responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at 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 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 advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

Lance Jon Kimmel, Esq.
SEC Law Firm
November 29, 2006 Page 3
Please contact Kurt Murao, Attorney Advisor, at (202)  551-3338, or Ellie
Quarles, Special Counsel, at (202) 551-3238 or me at (202) 551-3720 with any other
questions.

Sincerely,

      H. Christopher Owings
     A s s i s t a n t  D i r e c t o r

cc: Fax: ( 310) 388-1320