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    SEC
      LAW FIRM

    11693
      San Vicente Boulevard, Suite 357

    Los
      Angeles, CA 90049

    Tel.
      310-557-3059

    Fax.
      310-388-1320

    www.seclawfirm.com

    December
      11, 2006

    Ms.
      Ta
      Tanisha Henderon

    Ms.
      Donna
      DiSilvio

    United
      States Securities and Exchange Commission

    Division
      of Corporation Finance

    Washington,
      D.C. 20549

    Dear
      Ms.
      Henderson and Ms. DiSilvio:

    NuWay
      Medical Inc. (the “Registrant”) is responding to the written comments of the
      staff (the “Staff”) of the United States Securities and Exchange Commission (the
“Commission”) dated September 21, 2006 (the “Comment Letter”). The Registrant’s
      responses are keyed to the numbered comments of the Staff contained in the
      Comment Letter, which are set forth in full below immediately preceding each
      response.

    The
      Registrant believes that, as suggested by the Staff, it can modify its
      disclosure, as appropriate, in future filings and requests that the Staff
      confirm its concurrence with this proposed approach to addressing the Staff’s
      comments and that no amendment of any filing is required by the
      Staff.

    Form
      10-KSB for the Fiscal Year Ended December 31, 2005

    Cover
      Page

              1.

              Please
                revise your commission file number to
                000-19709.

    Response:
      The
      Registrant will revise its Commission file number in all future Exchange Act
      filings.

    Item
      8A. Controls and Procedures, page 25

              2.

              You
                state that your management evaluated the effectiveness of your disclosure
                controls and procedures, as defined in Exchange Act Rule 13a-15(e).
                However, your principal executive and financial officers only concluded
                that your disclosure controls and procedures were effective with
                regard to
                certain parts of the definition of disclosure controls and procedures.
                In
                future filings, please revise your disclosure regarding effectiveness
                to
                include the entire definition of disclosure controls and procedures
                in
                Exchange Act Rule 13a-15(e). Additionally, please confirm to us that
                your
                conclusion regarding effectiveness would not change had such disclosure
                been included in this filing.

    Response:
      In
      future filings, the Registrant will revise its disclosure regarding
      effectiveness to include the entire definition of disclosure controls and
      procedures in Exchange Act Rule 13a-15(e). Additionally, the Registrant confirms
      to the Staff that its conclusion regarding effectiveness would not have changed
      had such disclosure been included in this filing.

    Notes
      to Financial Statements

    Note
      8. Loan Agreement - Augustine Loan, page F-18

              3.

              Please
                tell us and revise your disclosures to state where you recorded the
                proceeds allocated to the warrants issued in conjunction with the
                Augustine Loan Agreement.

    Response:
      The
      proceeds allocated to the warrants in the amount of $245,000 was recorded as
      Discount on Notes, Net in the balance sheet when it was originally recorded
      in
      2003. As of December 31, 2003, the amount of $62,131 was reflected in the
      balance sheet. The amounts amortized during 2003 and 2004 and charged to
      interest expense were approximately $181,500 and $61,500,
      respectively.

    Form
      10-QSB for Fiscal Quarter Ended June 30, 2006

    Statements
      of Operations for the … periods ended June 30, 2006 and 2005

              4.

              Please
                revise your net loss per share calculations for the three months
                ended
                June 30, 2006 and 2005 to reflect a figure of $(0.00) or
                null.

    Response:
      In
      future filings, the Registrant will revise the net loss per share calculations
      for the three months ended June 30, 2006 and 2005 to reflect a figure of
      $(0.00).

              5.

              We
                note the revisions to the New Millennium Note which resulted in reduced
                principal and interest totaling approximately $282,000, however it
                is not
                clear if these revisions relate to the reduction to note payable
                and
                accrued interest reflected on the statements of operations in the
                amount
                of $362,320. Please clarify for us and revise
                accordingly.

    Response:
      The
      reduction in principal and interested totaling approximately $282,000 consists
      of a reduction of principal in the amount of $220,000 and a reduction in
      interest in the amount of $62,320, or a total of $282,320. The discrepancy
      between this aggregate amount and the amount of $362,320 reflected in the
      statement of operations is the further result of a clerical error in the amount
      of $80,000. The correct amount that should have been reflected in the statement
      of operations is $282,320. The Registrant noticed the error and filed an amended
      Quarterly Report on Form 10-QSB on November 17, 2006, correcting such error
      in
      the statement of operations.

    Statements
      of Cash Flows for the Six Month Periods Ending June 30, 2006 and
      2005

              6.

              Please
                identify the loans from which you received proceeds in the notes
                to the
                financial statements. In addition, it is not evidence that he reduction
                to
                Note Payable was a cash transaction. Please tell us how the note
                was
                reduced and revise your disclosure as
                appropriate.

    Response:
      As
      indicated in Note 4 to the Notes to Financial Statements, the Registrant
      received proceeds from promissory notes in three different offerings. The terms
      of the loans involved in each of these offerings are described under the
      headings “First Offering”, “Second Offering” and “Third Offering”. Separately,
      the reduction to the note payable in the amount of $282,320 was not a cash
      transaction. The reduction came about as a result of negotiations between New
      Millennium Capital Partners, LLC (“New Millennium”) and the Registrant,
      culminating in an agreement on April 28, 2006, as indicated in Note 7 to the
      Notes to Financial Statements, to amend the promissory note issued by the
      Registrant to New Millennium (the “New Millennium Note”) to (i) extend the due
      date to January 15, 2008; (ii) waive any payments of interest until the New
      Millennium Note becomes due; (iii) reduce the principal amount of the New
      Millennium Note from $1,120,000 to $900,000, equal to New Millennium's basis
      in
      said Note; and (iv) correspondingly reduce the accrued but unpaid interest
      due
      under the terms of the New Millennium Note from $317,956 to $255,636. The
      Registrant believes that the existing disclosure explains both the terms of
      the
      loans made as part of the First Offering, Second Offering and Third Offering,
      as
      well as the circumstances surrounding the reduction of the principal of, and
      accrued but unpaid interest on, the New Millennium Note. However, the Registrant
      is willing to make additional disclosure in future filings if the Staff believes
      that such disclosure would be meaningful.

    In
      connection with the foregoing response, the Registrant acknowledges
      that:

              ·

              It
                is responsible for the adequacy and accuracy of the disclosure in
                its
                filings;

              ·

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

              ·

              The
                Registrant 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.

    Please
      respond to the undersigned with any further comments or any other communications
      regarding the Comment Letter.

              Very
                truly yours,

              /s/
                Lance Jon Kimmel

              Lance
                Jon Kimmel