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Via Facsimile and U.S. Mail
Mail Stop 4720

         September 8, 2009

Les M. Taeger
Senior Vice President and Chief Financial Officer
OrthoLogic Corp.
1275 West Washington Street, Suite 101
Tempe, AZ 85281

Re: OrthoLogic Corp.
 Form 10-K for Fiscal Year Ended December 31, 2008
Form 10-Q for the Fiscal Quarter Ended June 30, 2009
 File Number:  001-33560

Dear Mr. Taeger:

We have reviewed your filings and have the following comments.  We have
limited our review to your fi nancial statements and relate d disclosures and do not intend
to expand our review to other portions of  your document.  We think you should amend
your Form 10-K in response to comment one.  If you disagree, we will consider your
explanation as to why our comment is inappl icable or a revision is unnecessary.  Please
be as detailed as necessary in your explan ation.  In comment two, we ask you to provide
us information and to revise your disclosure  beginning with your next Form 10-Q.

 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 filings.  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.

Form 10-K for the Fiscal Year Ended December 31, 2008

Financial Statements
Report of Independent Registered Public Accounting Firm, page F-1
 1. Please amend your filing to include the repor t of the auditors referred to by Ernst
& Young that covers the period fr om inception through December 31, 2005,
which complies with Rule 2-02 of Regulation S-X.  Refer to Rule 2-05 of Regulation S-X.

Les M. Taeger
OrthoLogic Corp.
September 8, 2009
Page 2

Form 10-Q for the Fiscal Quarter Ended June 30, 2009
Item 4 – Controls and Procedures, page 14

2. Your disclosure includes a partial definiti on of disclosure controls and procedures
rather than the complete definition of  disclosure controls and procedures
contained in Exchange Act Rule 13a-15(e).  Specificall y, confirm to us that your
officers concluded that your di sclosure controls and pro cedures are also effective
to ensure that information required to be disclosed in the repo rts that you file or
submit under the Exchange Act is acc umulated and communicated to your
management, including your chief executive officer and chief financial officer, to
allow timely decisions regarding required disclosure, and that you will include this complete definition in future filings.

* * * *

 Please amend your Form 10-K and respond to these comments within 10 business
days or tell when you will provide us with a response.  Please furnis h a cover letter with
your amendment that keys your responses to our  comments.  Detailed cover letters greatly
facilitate our review.  Please furnish your  letter on EDGAR under the form type label
CORRESP.  Please understand th at we may have additional comments after reviewing your
amendment and responses to our comments.

 We urge all persons who are responsible  for the accuracy and adequacy of the
disclosure in the filings to be certain that  the filings include all information required
under the Securities Exchange Act of 1934 and that 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 do not
foreclose the Commission from taking a ny action with respect to the filings;
and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

 In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.

Les M. Taeger
OrthoLogic Corp.
September 8, 2009
Page 3
 Please contact Staci Shannon, Staff Acc ountant, at (202) 551-3374 or Carlton
Tartar, Accounting Branch Chie f, at (202) 551-3387 if you ha ve any questions regarding
these 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