SecProbe.io

Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                 August 22, 2006
   Mr. Les M. Taeger Senior Vice President and Chief Financial Officer Orthologic Corp. 1275 W. Washington Street Tempe, AZ  85281
Re: Orthologic Corp.
 Form 10-K for the year ended December 31, 2005
Filed on March 13, 2006
 Form 10-Q for the interim period ended June 30, 2006
File No. 000-21214

Dear Mr. Taeger:

We have limited our review of your filing to those issues we have addressed in
our comments.  In some of our comments we ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.  Where indicate d, we think you should revise your documents
in response to these comments.  If you disagr ee, we will consider your explanation as to
why our comment is inapplicable or a revi sion is unnecessary. Please be as detailed as
necessary in your explanation.

 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 on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Les M. Taeger
Orthologic Corp. August 22, 2006 Page 2
 Form 10-K for the year ended December 31, 2005

 Management’s Discussion and Analysis of  Financial Conditions and Results of
Operations
 Liquidity and Capital Resources, page 32

1. Please revise your disclosure to expand disc ussions of your financial obligations for
2006 and 2007 as they relate to the contract ual obligations table.  You disclose
accrued clinical expenses of  $544,000, additional commitment due to clinical sites of
$988,000, and contracts to consultants and ot her contractual obligation, however the
sum of these amounts are a fraction of the “total liabilities” caption disclosed for 2006
and 2007 in your table.  Additionally, revise  your contractual obligations table to
comply with the format prescribed in  Item 303(a)(5) of Regulation S-K.

Financial Statements
 Notes to Financial Statements

 Summary of Significan t Accounting Policies

 D. Excess Space Reserve, page F-7

2. Please tell us why you have accrued a lia bility for excess space reserve and the
accounting literature management re lied upon to record this accrual.

Note 14. Subsequent Events, page F-19
 Sale of Shares of Company Stock, Issuance of  Warrants and Entry in to Master Services
Agreement, page F-20
3. Please tell us and disclose the significan t terms of your agreement with Quintiles
specifically the milestones that must be ach ieved in order for the stock warrants to
vest.

Form 10-Q for the interim period ended June 30, 2006
 Item 1. Financial Statements

 Notes to Unaudited Condensed Financial Statements

 C. Sale of Shares of Company Stock, I ssuance of Warrants and Entry into Master
Services Agreement, page 13

Mr. Les M. Taeger
Orthologic Corp. August 22, 2006 Page 3
 4. Please provide to us your analysis unde r EITF 00-19 of how you accounted for the
warrants issued to PharmaBio Development ( dba NovaQuest).  It appears that you are
required to issue registered sh ares to settle the contract and the number of shares that
must potentially be issued to settle the c ontract is infinite because at the time the
warrants were issued the stock price wa s unknown.  Based on this information, it
would appear that the warrants should have b een initially recorded as a liability with
changes in the fair market value recorded  through earnings in accordance with EITF
00-19.

Please amend your Form 10-K for the year ended December 31, 2005 and respond
to these comments within 10 business days of the date of this letter or tell us when you
will provide us with a response.  You may wish  to provide us with marked copies of the
amendment to expedite our review.  Please furnish a cover letter with your amendment
that keys your responses to our comment s and provides any requested information.
Detailed cover letters greatly facilitate our review.  Please file the letter on EDGAR under the form type label CORRESP.  Please understand that we may have additional
comments after reviewing your amendmen t and 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 include all information 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 co mments, please provide, in your letter, a
statement from the company acknowledging that:  ‚ the company is responsible for the adequacy  and accuracy of the disclosure in the
filings;
 ‚ staff comments or changes to disclosure in response to staff comments in the filings
reviewed by the staff do not foreclose th e 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 Di vision of Enforcement has access to all
information you provide to the staff of the Divi sion of Corporation Finance in our review
of your filing or in response to our comments on your filing.

Mr. Les M. Taeger
Orthologic Corp. August 22, 2006 Page 4
 You may contact Christine Allen, Staff Accountant, at (202) 551-3652  or Kevin
Woody, Branch Chief at (202) 551-3629  if you have questions regarding the comments.
In this regard, do not hesitate to contact me, at (202) 551-3679.
        S i n c e r e l y ,            J i m  B .  R o s e n b e r g
Senior Assistant Chief Accountant