SecProbe.io

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June 6, 2005

Gary Todd, Review Accountant
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

Re:      Advanced ID Corporation
         Form 10-KSB for the year ended December 31, 2004
         Form 10-QSB for the quarter ended March 31, 2005 File No. 000-24965
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Dear Mr. Todd:

Pursuant to your letter dated May 24, 2005 and in addressing each of the
comments contained therein, we acknowledge that we are responsible for the
adequacy and accuracy of the disclosures in our filings. We further acknowledge
that staff comments or changes to our disclosures in response to staff comments
in the filings reviewed by the staff do not foreclose the Commission from taking
any action with respect to our filings. Lastly, we acknowledge that we 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.

Item 6. Management's Discussion and Analysis of Financial Condition and Results
of Operations - Pages 16-18.
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Critical Accounting Policies and Estimates.
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1. Your comment is duly noted and will be complied with in future filings.

Results of Operations - Page 16.
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2. Your comment is duly noted and will be complied with in future filings.

Financial Statements.
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Report of Independent Registered Public Accounting Firm - Page 19.
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3. Our auditors also raised the question about our ability to continue as a
going concern during their audit of our financials for the two years ended
December 31, 2004. It is our belief that the audit report should not be modified
to include a going concern disclosure based on the following. We have projects
in a number of countries at different stages of completion. We are reasonably
confident we will be able to secure a significant order from Thailand where we
have been trialing our technology for nearly one year. We have recently
finalized our proposal for Thailand's Animal Identification Program for
presentation to the Minister of Agriculture. There are no other companies
competing for this business as no other technology has met the government's
complete requirements. We are expecting this contract to be finalized before the
end of the second quarter. This contract would represent revenues of US$46.6
million in Year 1 and US$94.0 million over 3 years. Our tags will be priced at
US$2.00 for the first year, $1.80 for the second year and $1.60 for the third
year. Our current costs to manufacture these tags are approximately $0.85 per
tag so we will earn a healthy margin. In the first year, the sale of our tags
would represent $37.5 million of the $46.6 million total. For the three year
contract total of $94.0 million, the sale of our tags would be $84.3 million.
<PAGE>

In Australia, their sheep industry has targeted 2005 to implement an
identification and trace back system. Once again, our competitors' technology
has not met the requirements of this industry whereas our technology offers
significant advantages. Although this does not guarantee us a contract, we
firmly believe we will be able to commercialize our technology in Australia as
well.

In the United States, we recently received an order from the New York Department
of Agriculture to trial our technology for the identification and trace back of
captive deer and elk, and which the Department requires all producers to
identify. Given the Department's interest to secure a product that offers a long
read range and can read multiple tags, we are currently the only technology that
offers these benefits. It is expected that should our product meet their needs,
the Department will require producers to utilize our technology. It is expected
that their adoption of an identification and trace back technology will occur in
2005 and most likely lead to the adoption of our technology in other states.

If these and other sales do not materialize, our first course of action would be
to clamp down on expenditures. We would eliminate certain consulting contracts
and possibly lay off certain employees. We would limit R&D to those areas such
as Thailand where we have products ready to go without any further R&D or that
would require minimal fine tuning.

In addition to this, we recently received an effective date of May 12th at 4:30
p.m. ET regarding our Form SB-2 to register 3.5 million shares and 3.5 million
warrants. Registration of these shares and warrants will provide us with a
mechanism to raise capital. Please contact David Ritenour, Special Counsel for
the Commission (202-942-7924) for confirmation regarding our Form SB-2
registration statement. We have been in discussion with four funding groups for
several months regarding a future financing. Two of the four funding groups have
expressed that they would provide us with a bridge financing should we need it
in advance of securing a significant contract.

Our revenues to date have been almost exclusively from our companion animal
division where we have been a reseller of AVID USA's products since 1994. We
expect this business to remain consistent with our revenues from the previous
two years.

Balance Sheet - Page 20.
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4. The typographical error of $25,492,200 has been deleted and the proper total
of $51,952 correctly corresponds to the caption title, trade accounts
receivable.

Note 1 - Business and Summary of Significant Accounting Policies - Page 24.
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Revenue recognition - Page 24.
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5. For our companion animal/biological sciences division, we earn revenues from
the sale of microchips/readers/collar tags and from pet registrations in our pet
recovery database. We record revenues when products are shipped to our customers
or when pet owners register their pet in our database. Currently, in excess of
90% of our customers pay us in advance by credit card before we ship product to
them or list them on our database. The only exceptions are approximately 8 to 10
long term customers who buy microchips and readers from us and who we give
payment terms of 30 days. The only services we provide on the companion
animal/biological sciences division is in regard to our pet recovery database.
For most of our customers, their purchase of one of our microchips provides them
with a free registration in our pet recovery database. The only time we charge
pet owners to register their pet in our database is when there is a change in
ownership of a pet or when pet owners with competitors' microchips wish to
register their pet on our database. In both cases, we require payment prior to
adding their information on our database. Revenue in these cases is recorded
once we have received payment and they have been added to our database. Should
someone lose their pet, our commitment to our registered pet owners is to
provide the party who has found a lost or stolen pet with the requisite contact
information of the pet owner so that the pet can be returned to its rightful
owner. This pet recovery service is provided for the life of the pet. We charge
a one-time fee of $25.00 for a pet registration or a change of ownership. Our
total revenues for pet recovery registrations for fiscal 2004 were CAD
$15,144.14 which was 1.3% of our total revenues of CAD $1,166,122.49 and which
we view as immaterial.
<PAGE>

With regard to our livestock division, we have only sold tags and readers to
date and it is not our intent to sell our software. It is our intent to give our
software away as a means to provide a complete solution and to encourage the
sale of our tags and readers. We will not be setting up a recovery database as
we have done in the companion animal/biological sciences division. This
information will be managed by the various governments in which we are dealing.
Our revenues will be recognized once products are shipped.

Since revenues from our pet recovery service are immaterial, any deferral of
these revenues would also be immaterial. Consequently, we firmly believe our
revenue policy complies with GAAP.

6. We would agree with your comment that it is not likely our microchips would
be purchased for pets without our pet recovery services. In the event one of our
registered pet owners loses their pet and it is recovered by an animal shelter
or SPCA, the animal shelter or SPCA would contact us (or one of our competitors
in the event it is not one our microchips) and provide us with the pet's unique
identification number. Our staff would key in this number into our database from
their computer at which time, the contact information of the pet owner would be
displayed. This contact information would be relayed to the animal shelter or
SPCA who would then contact the pet owner to return the lost pet. A typical pet
recovery phone call takes approximately 2 minutes. Consequently, we would agree
that SAB Topic 13A.3.f. is applicable, however, we view our revenues from this
service as being immaterial in relation to our total revenues, the service would
only be required in the event of a pet becoming lost and then recovered, and the
deferral of such revenues would in itself be immaterial.

7. There exist no contracts with any of the distribution agencies we deal with
in Canada. We provide them with a price list and offer them payment terms of 30
days. Our end customer is the distribution agency in most cases. In the few
cases where we sell directly to the veterinarian, we book these revenues once
the product is shipped. Once the distribution agencies buy product from us, they
in turn distribute to individual veterinarian offices. We do not accept any
returns unless it is a defective product at which time we would replace the
defective product with an identical product. All products sold are final with no
opportunity to return them so we firmly believe under GAAP that we can recognize
revenue once it is shipped.

8. We provide no training, installation, upgrades or future services with regard
to our products and we are under no obligation for such. Should any of our
customers have questions regarding any of our products, we will assist them as a
matter of good customer service but we are under no obligations to perform such
services. As noted in comment 7, we do not accept returns unless the product is
defective at which time we will replace that item.

9. All products shipped for an evaluation or field trial have been done at our
expense with the exception of a trial with the New York Department of
Agriculture whereby we received a purchase order in May 2005. In the second
quarter of 2005, we will recognize the revenues for the New York purchase order
once the products have been shipped. These products are being trialed to
determine if they should proceed with further orders. Once these products are
shipped and paid for, there is no opportunity for them to return them to us
unless they are defective, at which point we would replace them. When we use the
words, field trial or evaluation, it is from the context of seeing how our
technology works within our customers' own environments. The products we are
shipping to them are finished products and are not prototypes. As a new
technology, we have found that to gain traction for our products we have footed
the cost of tags and readers in our field trials around the world. As of
relatively recently, if someone is interested in evaluating our technology they
must pay for it and there is no opportunity for them to give it back to us and
receive their money back.
<PAGE>

10. We would agree that the guidance from EITF 00-21 is relevant to our
companion animal business which involves a multiple element to our revenues. We
understand that we have future costs associated with certain revenues; however,
we view such costs as immaterial. Our service revenues related to our pet
recovery service represented 1.3% of our total revenues for 2004 and in our
viewpoint are immaterial; the subsequent deferral of such revenues over the
average lifespan of a pet of 8 to 10 years would also be immaterial; the costs
associated with providing a pet recovery service which on average takes 2
minutes to relay contact information to the caller is also immaterial; and such
a service would only be required in the event of a lost pet which has been
subsequently recovered.

Stock Options - Page 26.
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11. Of the total number of options issued in 2004, none had become vested in
2004. Fifty percent of the 2004 options were to have vested after the first
anniversary and the balance was to have vested after the second anniversary.
Therefore no additional expense was booked in 2004 and the pro forma impact of
fair value accounting of the options did not change from what they were
calculated to be as at December 31, 2003.

Note 2 - Common Stock - Page 27.
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12. Your comment is duly noted and we will add the following additional
information in future filings.

We had accounted for the $1 million debenture as follows. The note accrued
interest at 1%; therefore Advanced ID discounted the payments due under the
agreement using a discount rate of 18% percent and recorded as a discount to the
note totaling $562,891. This discount was to be amortized over the five year
term of the note as interest expense. A discount rate of 18% was used because it
represented an appropriate risk adjusted rate given our current level of
operations, and it was the same rate that we were paying on an outstanding note
at the time.

In addition, under generally accepted accounting principles, we had recorded the
value of the beneficial conversion feature of these convertible debentures as a
debt discount. The debt discount recorded related to the beneficial conversion
feature was $437,109. This debt discount was to be amortized and charged to
interest expense over the five year term of the debenture agreements. Since the
investors converted the debentures prior to maturity of the agreements,
generally accepted accounting principles required us to expense the unamortized
balance of the debt discount in full. The total amount of the beneficial
conversion and debt discounts recorded was $969,180, the value of the net
proceeds received by the company.

Note 4 - Commitments - Page 29.
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13. Your comment is duly noted.

Note 5 - Stock Options and Warrants - Page 30.
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14. Your comment is duly noted and we will add the requested information to our
future filings.

Reportable Segments.
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15. Your comment is duly noted and we will add the requested information to our
future filings.

Item 8A. Controls and Procedures - Page 33.
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16. Your comment is duly noted and we will make the requisite changes as
directed.

17. Your comment is duly noted.

18. Your comment is duly noted and we will make the requisite changes as
directed.
<PAGE>

Section 302 Certification - Exhibit 31 - Pages 40 and 41.
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19. Completed as requested. We have re-filed our Form 10-KSB and Form 10-QSB
with the required changes to our certifications.

Sincerely,

Todd Noble,
Chief Financial Officer

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