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      Response letter to the SEC

      Letterhead
        of The Amacore Group, Inc.

      (formerly
        Eye Care International, Inc.)

      November
        2, 2005

      Ms.
        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
        October 17, 2005, we provided a comprehensive response to your comment letter
        dated September 22, 2005. Subsequently, on October 19, 2005, we held a
        teleconference with the Staff to discuss our response. As an outcome of that
        teleconference, we would like to amend certain elements of our October 17,
        2005
        response. We have made reference herein to our letter of October 17,
        2005.

      COMMENT

      Financial
        Statements

      Financial
        Statements for the six months ended June 30, 2005

      Note
        8—Convertible Debentures

      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.

          Page
            2

      RESPONSE

      Series
        C Preferred Stock:

      We
        initially applied FAS150 Accounting
        for Certain Financial Instruments with Characteristics of both Liabilities
        and
        Equity
        to our
        accounting for the issuance of our Series C Preferred Stock. In our application
        of FAS150, we classified the Series C Preferred Stock as a liability and
        carried
        it at fair value. We have revised our accounting to account for the Series
        C
        Preferred Stock under ASR 268 Redeemable
        Preferred Stock
        and, as
        it relates to the embedded conversion feature, under EITF 00-19 Accounting
        for Derivative Financial Instruments Indexed to, and Potentially Settled
        in, the
        Company’s Own Stock.

      Our
        revised accounting provides for allocation of the proceeds ($602,000) from
        the
        offering first to the embedded conversion feature. This allocation methodology
        is consistent with Implementation Issue B-6, referred to in our letter of
        October 17, 2005. The proceeds were not sufficient to fully record the embedded
        derivative. Therefore, a charge to income amounting to $469,782 was recorded
        to
        adjust this derivative financial instrument to fair value. Our previous
        accounting provided for recognition of the warrants issued concurrently with
        the
        Series C Preferred Stock as current liabilities, and at fair value. Since
        proceeds were fully applied to the embedded conversions feature, we have
        recorded a charge to income of $976,000, representing the fair value of the
        warrants.

      We
        have
        now applied ASR 268 to accounting for the Series C Preferred stock and, as
        a
        result, have classified this instrument as a mezzanine security subject to
        accretion up to the redemption value of $860,000. We have also reflected
        reconciliation between net loss and loss applicable to common stockholders
        on
        our statements of operations.

      Existing
        Derivative Financial Instruments:

      Our
        response of October 21, 2005 did not address paragraph 24 of EITF 00-19.
        Paragraph 24 requires the Issuer to consider the effects of EITF 00-19 on
        existing derivative financial instruments. We have considered the requirements
        of paragraph 24 and have concluded that other derivative financial instruments,
        principally outstanding warrants, required reclassification from equity to
        liability because the Company became unable to control physical or net-share
        settlement upon issuance of the convertible debentures and the Series C
        Preferred Stock.

      We
        reclassified an amount equal to the fair value of these instruments ($3,545,000)
        from stockholders’ equity to current liabilities and have adjusted this
        liability to fair value in subsequent periods.

      Income
        Statement Classification of Fair Value Adjustments:

      In
        our
        response of October 21, 2005, we reported the fair value adjustments to the
        derivative financial instruments as components of interest expense. Given
        the
        significance of these amounts, we have changed that classification to provide
        for a separate line item, within other income and expense, to reflect these
        adjustments.

          Page

      Liquidating
        Damages:

      The
        terms
        of our 6% and 7% convertible debentures provide for liquidating damages of
        2%
        per month if, after 150 days from closing, the Issuer has not obtained and
        effective registration statement. Our accounting reflected in our October
        17
        response reflected provisions for these liquidating damages. However, we
        reconsidered what the definition of “closing.” As a result of our
        considerations, we have calculated our adjustment with “closing” representing
        the first date that the holder had the right to convert or exercise any rights
        under the instruments. As a result, there is no change in the accounting
        provided in our October 17 response. In the financial information we provided
        on
        October 17, 2005, $43,690 and $32,300 had been charged to income during the
        six
        months ended June 30, 2005 and the year ended December 31, 2004,
        respectively.

      We
        have
        provided prominent footnote disclosure of this recorded liability in our
        convertible debentures footnote and in management’s discussion and
        analysis.

      *
        * * *
        *

      The
        conclusions reached in this letter and those conclusions in our October 17,
        2005
        letter that continue to be appropriate are incorporated in Amendment No.
        8
        (attached hereto) to our Registration Statement on Form SB-2/A. For your
        convenience, I have also attached a red-line Word version of Amendment 8
        showing
        the changes made to the Amendment 7 version.

      Our
        independent accountants, Brimmer, Burek & Keelan LLP, have reviewed these
        responses and revised financial statements and concur with same.

      We
        appreciate your consideration of our revised conclusions to your comment
        of
        September 22, 2005. We would appreciate you giving this your immediate attention
        as we would like to formerly file the amended SB-2/A yet today, if possible,
        or
        tomorrow at the latest. We would be pleased to discuss, either by telephone
        or
        in person (if necessary) any questions you may have, if any.

                Sincerely
                  yours,

               /s/ James
                L. Koenig

                James
                  L. Koenig

                Acting
                  Chief Financial Officer

              cc:

                David
                  J. Levenson, Esq.

                Michael
                  McTiernan

                Cicely
                  Luckey

                Robert
                  Telewicz