SecProbe.io

Mail Stop 3561
  January 26, 2007

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

Re: NuWay Medical, Inc.
 Amendment No. 1 to Preliminar y Proxy Statement on Schedule 14A
 Filed January 8, 2007
  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. We note your response to comment 1 in  our letter dated November 29, 2006
indicating that you have submitted a re sponse to us on December 11, 2006.  As
further comments have been issued, please comply with any outstanding
comments that were issued as part of our  review of your Form 10-KSB for fiscal
year ended December 31, 2005 and Form s 10-QSB for fiscal quarters ended
March 31, 2006, June 30, 2006 and September 30, 2006.

Lance Jon Kimmel, Esq.
SEC Law Firm
January 26, 2007 Page 2
2. We note that you have included the bulleted representations that we requested at
the end of the response letter.   Please note that these representations must come
from the registrant directly  under separate cover.

Proposal 1, page 2
Executive Compensation, page 8
3. Please update and revise your disclosure to comply with the new executive compensation disclosure rules which went effective on November 7, 2006 for
years ending on or after December 15, 2006.  See SEC Release No. 33-8732A (August 29, 2006).

Proposal 2, page 13
4. Please expand your disclosure to provide the information required by Item 303 of
Regulation S-K as to IOWC Technologies , Inc.  See Item 14(c)(2) of Schedule
14A and Item 17(b)(5) of Form S-4.

Background of the BioLargo Transactions, page 15
5. We note your response to comment 2 in  our letter dated November 29, 2006.
Please expand your disclosure to more  fully and specifically discuss the
consideration negotiations between you and IOWC, including the relevant dates
that resulted in the determination th at you will issue a total of 553,475,300 shares
of common stock for certain technology and rights re lating to the BioLargo
Technology.

* * *

 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.

Lance Jon Kimmel, Esq.
SEC Law Firm
January 26, 2007 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