SecProbe.io

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Mail Stop 0306

May 13, 2005

J. Richard George
Chief Executive Officer
Calypte Biomedical Corporation
5000 Hopyard Road, Suite 480
Plesanton, California 94588

Re:	Calypte Biomedical Corporation
      Amendment No. 3 to Form SB-2 on From S-3
      Filed April 27, 2005
      File No. 333-124344

Dear Mr. George:

	We have limited our review to selected portions of your
registration statement, and we have the following comments.  Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

      Please understand that the purpose of our review 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.

General
1. Please reconcile (1) your registration statement facing page
which
identifies the filing as an amendment with (2) the Edgar tag you
chose to use which identifies your filing as a new registration
statement.  If you are not registering additional securities, you
should not file a new registration statement.  If your intention
is
solely to create a single prospectus per Rule 429, you should file
a
post-effective amendment to the latest registration statement that
registered securities that are
 the subject of the single prospectus.  The filing should comply
with
the last sentence of Rule 429(b).
2. Please submit as correspondence on EDGAR your May 2, 2005, May
3,
2005 and May 8, 2005 letters.

 Prospectus Cover Page
3. Please provide a one-page prospectus cover that is limited to
required information and information that is key to an investment
decision.  For example, it is unclear why the previous
registration
status is relevant to investors who are considering whether to
purchase the securities offered by the prospectus.

Exhibit 5.1
4. The opinion that you file as an exhibit must be based on
applicable law and may not assume that that law is similar to some
other jurisdiction.  We note that the opinion you filed
impermissibly
assumes that Delaware law is the same as California law.
5. Please ask your counsel to submit via Edgar a confirmation that
it
concurs with our understanding that its reference "General
Corporation Law of the State of Delaware" includes the statutory
provisions and all applicable provisions of the Delaware
Constitution
and reported judicial decisions interpreting these laws.
6. Please tell us why the assumptions mentioned in the fourth
paragraph following paragraph (h) are necessary and appropriate
for
the shares that are already outstanding.

*          *          *
      As appropriate, please amend your registration statement in
response to these comments.  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 comments and provides any requested
supplemental information.  Detailed cover letters greatly
facilitate
our review.  Please understand that 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 reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

?	the company may not assert staff comments and the declaration
of
effectiveness 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 Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment
for further review before submitting a request for acceleration.
Please provide this request at least two business days in advance
of
the requested effective date.

      You may contact Tom Jones at (202) 942-1927 or me at (202)
824-
5697 with any questions.
      Sincerely,

							Russell Mancuso
      Branch Chief

cc (via fax): Paula Winner Barnett, Esq.

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Calypte Biomedical Corporation
May 13, 2005
Page 4

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