SecProbe.io

Mail Stop 3561
  February 5, 2007

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

Re: NuWay Medical, Inc.
 Amendment No. 2 to Preliminar y Proxy Statement on Schedule 14A
 Filed February 1, 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.

Background of the BioLargo Transactions, page 5
1. We note your response to comment 5 in our letter dated January 26, 2007.  In
your revised disclosure, you state that you “[e]ngaged third party consultants who
informally confirmed [y]our management ’s own belief that the value of the
BioLargo Technology was in a range, even the lower end of which significantly exceeded the then-current value of 51% of [y]our common stock.”  You further
disclosed, “We did not seek a formal appr aisal or fairness opinion of the value of
the BioLargo Technology given our limited resources….”  Please tell us whether the company received any type of report from the third party consultants that
would fall under Item 14(b)(6 ) of Schedule 14A.  If so, Item 14(b)(6) of Schedule
14A requires that you furnish the information required by Item 1015(b) of Regulation M-A.

Lance Jon Kimmel, Esq.
SEC Law Firm
February 5, 2007 Page 2

* * *

 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.

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