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CORRESP
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      Request for Aceleration

    November
      8, 2005

    By
      Facsimile: (202) 772-9209

    Mr.
      Michael McTiernan, Special Counsel

    Securities
      and Exchange Commission

    100F
      Street, NE

    Washington,
      D.C. 20549

            Re:

              The
                Amacore Group, Inc.

              (formerly
                Eye Care International, Inc.)

              Registration
                Statement on Form SB-2/A

              Filed
                November 4, 2005

              Registration
                No. 333-121308

    Dear
      Mr.
      Tiernan:

    In
      response to your November 8, 2005 email to me, we respectfully request
      acceleration of the effective date of the above-referenced registration
      statement to 1 p.m. on Wednesday, November 9, 2005, or as soon thereafter as
      possible.

    In
      the
      comment letter dated January 13, 2005 and July 27, 2005, Elaine Wolff, Branch
      Chief, called our attention to Rules 460 and 461 of the Securities Act of 1933
      concerning requesting acceleration of the effective date of the registration
      statement. With respect to Rule 460, the registrant has made no distribution
      of
      the preliminary prospectus. However, the registrant shall provide copies of
      the
      prospectus included as part of the effective registration statement to all
      selling security holders together with a letter bringing to their attention
      certain matter of importance concerning certain statutory provisions of the
      SEC
      and its rules and regulations applicable to all selling security holders, to
      assist them in understanding their responsibilities under the federal securities
      laws and Regulation M in connection with their offer and sale of their shares,
      including: the requirement to deliver a prospectus; the need to notify us when
      their offer and sale of shares is complete; the prohibition of bidding for
      or
      buying any shares in the market, directly or indirectly, until the offer and
      sale of shares of all selling security holders is complete; and the prohibition
      of making any representations or giving any information about the registrant
      or
      its securities that is not contained in the prospectus. With respect to Rule
      461, in requesting acceleration, the registrant is aware of its obligations
      under the Securities
      Act of 1933 and those of the selling security holders to comply with Regulation
      M.

    The
      registrant acknowledges:

              (1)

              that
                should the Commission or 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,

              (2)

              that
                the action of the Commission or the Staff, acting pursuant to delegated
                authority, in declaring the filing effective, does not relieve the
                registrant from its full responsibility for the adequacy and accuracy
                of
                the disclosure in the filing, and

              (3)

              that
                the registrant may not assert this action as defense in any proceeding
                initiated by the Commission or any person under the federal securities
                laws of the United States.

    Thank
      you
      for your attention.

    Sincerely,

    /s/
      James
      L. Koenig

    James
      L.
      Koenig

    Acting
      Chief Financial Officer

    cc:
      David
      J. Levenson