SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

      May 17, 2005

Mail Stop 4561 via U.S. Mail and Fax (305) 371-4112

Mr. Alan Jay Weisberg
Chief Financial Officer
Orthodontix, Inc.
1428 Bricknell Avenue, Suite 105
Miami, Florida 33131

RE:	Orthodontix, Inc.
	Form 8-K filed May 13, 2005
            File No. 0-27836

Dear Mr. Weisberg:

We have reviewed your filing and 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 me at the telephone number
listed
at the end of this letter.

1. Amend to provide the disclosures required by Item 304(a)(2)(i)
and
(ii) of Regulation S-K for the Company`s two most recent fiscal
years
and any subsequent interim period prior to engaging Salberg &
Company, P.A.

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.  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.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company 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.

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 our review of your filing or in response to
our comments on your filing.

Please provide the supplemental information requested above within
five business days from the date of this letter.  The supplemental
information should be filed as correspondence on EDGAR.

Any questions regarding the above should be directed to me at
(202)
551-3469.

						Sincerely,

						Thomas Flinn
						Staff Accountant

Orthodontix, Inc.
May 17, 2005

Page 1

</TEXT>
</DOCUMENT>