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CORRESP
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      Response to SEC Comments

    LAW
      OFFICES OF

    DAVID
      J. LEVENSON

    7947
      Turncrest Drive

    Potomac,
      Maryland 20854

              Admitted:
                MC, DC and VA

              (301)
                299-8092

              Fax:
                (301) 299-8093

              levensonfam@msn.com

              (Not
                Admitted: MD)

    September
      23, 2005

    Elaine
      Wolff, Branch Chief

    Securities
      and Exchange Commission

    100
      F
      Street, NE

    Washington,
      D.C. 20549

            Re:

              The
                Amacore Group, Inc.

              (formerly
                Eye Care International, Inc.)

              Registration
                Statement on Form SB-2/A

              Filed
                September 15, 2005

              Registration
                No. 333-121308

    Dear
      Ms.
      Wolff:

    On
      behalf
      of the registrant, we respectfully respond to your comment letter dated
      September 22, 2005 to Clark A. Marcus, President and Chief Executive Officer
      of
      the registrant.

    COMMENT

    Financial
      Statements

    Financial
      statements for the six months ended June 30,
      2005

    Note
      8 - Convertible Debentures

              1.

              We
                note your response to our prior comment 2. Tell us how you have considered
                SFAS 133 and EITF 00-19 in determining that the conversion feature
                on your
                convertible debt is not an embedded derivative.  In your response
                specifically address whether your obligation to issue shares upon
                conversion must be satisfied in registered shares.  Additionally,
                tell us whether any terms in the debt agreements would require net
                cash
                settlement.

    RESPONSE

    The
      Company has reviewed FAS 133 and EITF 00-19 to determine if the convertible
      debt
      should be considered as a derivative. In particular, it has compared paragraphs
      12-33 of EITF 00-19 to the convertible instrument with a view to determining
      if
      the embedded conversion feature would require bifurcation from the instrument
      to
      be considered as a standalone derivative.

    In
      review
      of the paragraphs 12-33, the Company is of the opinion that it meets the tests
      of those paragraphs so that the embedded conversion feature would be classified
      as equity and not as a liability and therefore not categorized as a standalone
      derivative. The Company is not obligated to satisfy the obligation by issuing
      registered shares. There are no terms in the agreement that would require a
      net
      cash settlement.

    As
      such,
      the convertible debenture and its embedded conversion feature should be
      accounted for under EITF 00-27. The Company has accounted for the discount
      associated with the conversion feature and expensed it as interest in the
      current period in accordance with the applicable paragraphs of EITF 00-27.
      Therefore, we believe that Form SB-2/A, Amendment No. 7, is correct as filed,
      without any further revisions.

    Thank
      you
      for your prompt attention and cooperation. If any additional information is
      desired or if there is any question, please contact me or Mr. Marcus by
      telephone.

              Sincerely,

              /s/
                David J. Levenson

              David
                J. Levenson

            cc:

              Michael
                McTiernan, Special Counsel

              Clark
                A. Marcus, President