SecProbe.io

CORRESP
1
filename1.htm

    corresp.htm

    September
16, 2009

    Jim B.
Rosenberg

    Senior
Assistant Chief Accountant

    United
States Securities and Exchange Commission

    100 F.
Street, N.E.

    Washington,
DC 20549

              Re:

              OrthoLogic
      Corp.

    Form 10-K
for the fiscal year ended December 31, 2008

    Filed on
March 13, 2009

    Form 10-Q
for the fiscal quarter ended June 30, 2009

    Filed on
August 12, 2009

    File No.
001-33560

    Your
letter dated September 8, 2009

    Following
is our response to your letter dated September 8, 2009.  We have
included your specific questions prior to our response to facilitate your
review.

    Form 10-K for the fiscal
year ended December 31, 2008

    Financial
Statements

    Report of
Independent Registered Public Accounting Firm, page F-l

                1.

                Please
      amend your filing to include the report of the auditors referred to by
      Ernst & Young that covers the period from inception through December
      31, 2005, which complies with Rule 2-02 of Regulation S-X. Refer to Rule
      2-05 of Regulation S-X.

    Our
Response:

    We concur
with your observation and will file an amended Form 10-K by or before September
30, 2009.  Our independent registered public accounting firm has
performed audit procedures to enable them to eliminate their reference to other
auditors and will reflect that change in their report included within the
amended Form 10-K.

    Form 10-Q for the fiscal
quarter ended June 30, 2009

    Item 4 -
Controls and Procedures, page 14

              2.

              Your
      disclosure includes a partial definition of disclosure controls and
      procedures rather than the complete definition of disclosure controls and
      procedures contained in Exchange Act Rule l3a-15(e). Specifically, confirm
      to us that your officers concluded that your disclosure controls and
      procedures are also effective to ensure that information required to be
      disclosed in the reports that you file or submit under the Exchange Act is
      accumulated 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.

    1275 West Washington Street●Tempe, AZ 85281●Tel
602-286-5414●Fax 602-926-2641●ltaeger@olgc.com

    Our
Response:

    We
specifically confirm to you that our officers concluded that our disclosure
controls and procedures are also effective to ensure that information required
to be disclosed in the reports that we file or submit under the Exchange Act is
accumulated and communicated to our management, including our chief executive
officer and chief financial officer, to allow timely decisions regarding
required disclosure.

    We will
include a complete definition in future filings.

    The
Company acknowledges 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 any action with respect to the
      filings; 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.

    Please
contact me if we can be of further assistance.

    Sincerely,

    /s/ Les M.
Taeger

    Les M.
Taeger

    Senior
Vice President and Chief Financial Officer

    OrthoLogic
Corp.

    1275 West
Washington Street●Tempe, AZ 85281●Tel 602-286-5414●Fax
602-926-2641●ltaeger@olgc.com