SecProbe.io

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                       SICHENZIA ROSS FRIEDMAN FERENCE LLP
                  1065 AVENUE OF THE AMERICAS NEW YORK NY 10018
             TEL 212 930 9700 FAX 212 930 9725 EMAIL: INFO@SRFF.COM

                                          November 4, 2005

Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549

Attn: Mr. Brian Cascio
      Mr. Gary Todd
      Mr. Patrick Enunwaonye

          Re:  Advanced Optics Electronics, Inc.
               Form 10-KSB for the fiscal year ended December 31, 2004
               Filed April 04,2005
               Form 10-QSB for the quarter ended March 31, 2005
               Form 10-QSB for the quarter ended June 30, 2005
               File No. 000-24511

Ladies and Gentlemen:

      We are special  counsel to Advanced  Optics  Electronics,  Inc.,  a Nevada
corporation  (the  "Company").  This letter responds to your letter dated August
18,  2005,   relating  to  comments  of  the  Staff  in   connection   with  the
above-referenced submission.

      The  responses  to the  Staff's  comments  are  numbered  to relate to the
corresponding comments in your letter.

FORM 10-KSB FOR THE YEAR DECEMBER 31, 2004

General
-------

    1.  File the amended Form 10-KSB referred to in your cover letter.

    Response: The Form 10-KSB/A has been filed.
    ---------

Results of Continuing Operations
--------------------------------

Operating Expenses, page 19
---------------------------

<PAGE>

Securities and Exchange Commission
October 26, 2005
Page 2 of 6

    2.  We refer to your  response to comment 6. Please  provide us schedules of
        the  underlying  calculations  of the gains and losses on the  debenture
        conversions.  Provide  explanation  about how you determined the amounts
        presented on those schedules. Show us how you measured the fair value of
        the stock issued in  satisfaction  of the notes.  If you used other than
        the quoted  market price of the shares on the  conversion  dates explain
        why your method conforms to GAAP.

    Response:  The last  paragraph  of Footnote 9 has been  expanded as follows:
    ---------

During  the year ended  December  31,  2004 in  accordance  with the  applicable
convertible  debentures  agreement,  the Company  issued  103,000,000  shares of
common stock at a conversion price of  approximately  $0.0109 in connection with
the  conversion  of notes  payable of  $505,060,  including  $166,240 of accrued
interest,  and  recorded  a loss  on  settlement  of  debt  of  $620,730.  Other
conversions  produced net losses of $250, for a total of $620,980.  A balance of
$102,977 is being carried for this debenture on the Company's  financial records
as of December 31. 2004.

During the year ended  December  31, 2003,  in  accordance  with the  applicable
convertible note payable  agreement,  the Company issued  320,830,452  shares of
common stock at conversion  prices of  approximately  $0.0021 in connection with
the  conversion of notes  payable.  These shares were issued to three  debenture
holders for a total value of $658,393 including accrued interest of $67,000.  At
the end of 2003 the Company repaid and retired two debentures for  approximately
$255,811 in cash; this was accounted for as approximately  $210,000 in principal
and  accrued  interest  of  approximately  $45,000.  The  balance  of these  two
debentures  on the  Company's  financial  records  was more  than the  repayment
amount,  resulting in a gain on retirement of debentures of $40,171.  Other such
retirements created net gains of $24,721, for a total of $64,892 for the year.

The following table summarizes these transactions:

                                                    2003             2004
                                                    ----             ----

Shares issued to retire debentures             320,830,452      103,000,000

Approximate value per share                       $ 0.0021          $0.0109
                                                  --------          -------

Total value of shares issued                       658,393        1,125,790

Cash payments rendered                             255,811

Carrying value of debt retired                     954,375          505,060
                                                   -------          -------

Gain (loss) on retirement of debt                 $ 40,171        $(620,730)
                                                  ========       ==========

<PAGE>

Securities and Exchange Commission
October 26, 2005
Page 3 of 6

    Form 10-Q as of June 30, 2005
    -----------------------------

Statements of Cash Flows, page F-4
----------------------------------

    3.  Disclosure on page F-9 indicates  that you  transferred  to  consultants
        approximately  14.5 million shares of GenoMed stock with a fair value of
        $390,366.  Tell us why the operating  section of the cash flow statement
        does not  present a  non-cash  charge  for the fair  value of the shares
        transferred.   Either  revise  or  explain  why  your   presentation  is
        appropriate under SFAS 95.

    Response:
    ---------

We have  revised the detail  relating  to the shares of GenoMed  stock that were
issued for  services:  4,571,000  shares were  transferred  to  consultants  for
services at a value of $290,839.  The operating section of the revised cash flow
statement ( See Exhibit A) presents a non-cash  charge for the fair market value
of $290,839.

An additional 9,900,000 shares of GenoMed were allocated as reserve for services
at a value of  $693,000.  In the third  quarter,  those  9,900,000  shares  were
restored  to  the  investment  inventory.  Anticipating  the  reversal  of  this
transaction,  we  charged  other  comprehensive  income  so as  not  to  distort
operating results.

We believe that this presentation conforms to SFAS 95.

The  following  is the  proposed  changes to  Footnote  1, under the  Marketable
Securities section, to clarify this issue:

     Available-for-sale  securities  consist of  securities  in GenoMed  and are
     carried  at fair  value  with  the  unrealized  gain or  loss,  net of tax,
     reported  in  accumulated  other  comprehensive  income.  The fair value of
     marketable  securities  was  determined  based on  available  market  price
     information on the dates of transactions.  During the six months ended June
     30, 2005, the Company  transferred  4,571,000  shares valued at $290,839 to
     consultants  in exchange for services.  An additional  9,900,000  shares of
     GenoMed were allocated as reserve for services at a value of $693,000.

    4.  As a related matter, confirm that the $293,347 identified as "Investment
        in GenoMed" is an actual  cash sale.  If these  shares were not sold for
        cash, either appropriately revise the cash flow statement or explain why
        the existing presentation is appropriate under SFAS 95.

    Response:
    --------

The  Statement  of Cash Flows has been  revised.  See  response to Comment 3 and
Exhibit A.

<PAGE>

Securities and Exchange Commission
October 26, 2005
Page 4 of 6

    5.  Provide us roll-forwards  from December 31, 2004 to June 30, 2005 of the
        number of GenoMed  shares and the fair  value of those  shares.  Present
        transactions and changes in fair value in gross amounts by quarter.

    Response:
    ---------

    See Roll-Forward below.

                        ADVANCED OPTICS ELECTRONICS, INC.
                            Genomed Stock Rollforward
                                    6/30/2005

                                                Shares               Amount
                                           ---------------      ---------------

Beginning balance, 12/31/04                   33,364,230         $    900,000
1/31 mark to market                                                    (9,096)
1/31 purchase                                     95,000                6,259
2/28 purchase                                     49,000                4,456
2/28 sale                                       (190,000)             (13,523)
3/31 purchase                                     87,000                8,055
3/31 mark to market                                                   994,847
3/31 consulting fees                            (571,409)             (15,411)
                                           ---------------      ---------------
Balance 3/31/05                               32,833,821            1,875,587
                                           ---------------      ---------------

4/30 purchase                                     11,000                1,017
5/31 sale                                        (81,098)              (5,148)
4/30 adjust to statement balance                                          189
6/30 reclassify balance from
       marketable securities                     529,098               59,462
6/30 consulting fees                          (4,000,000)            (275,428)
6/30 mark to market                                                   394,818
6/30 reserved for operating expense,
       other comprehensive income *           (9,900,000)            (693,000)

                                           ---------------      ---------------

Balance 6/30/05                               19,392,821         $  1,357,497
                                           ===============      ===============

                                                       -                    -

* Reserved shares were not issued in 2nd qtr. We had not returned said shares to
registrar at 6/30. Consequently, we could not verify that the shares had not
been issued. This amount will reverse in 3rd qtr. In order to not significantly
distort operating expense in two periods, we elected to put this on the balance
sheet, in other comprehensive income.

<PAGE>

Securities and Exchange Commission
October 26, 2005
Page 5 of 6

    Note 8, Stockholders' Equity, page F-15
    ---------------------------------------

    6.  You  disclose  that during the six months ended June 30, 2005 you issued
        21 million shares for  debentures.  Show us how you measured the $21,000
        fair value  assigned to those shares.  If you used other than the quoted
        market  price of the shares on the  conversion  dates,  explain why your
        method conforms to GAAP.

    Response:
    ---------

The footnote disclosure of $21,000 is incorrect; it is only the par value of the
transaction. The correct amount is $31,122, which includes $10,122 of APIC. This
was  correctly  recorded in the  financials,  and footnote 8 has been revised to
show the  correct  amount.  This was  calculated  by formula  prescribed  in the
original agreement at the issuance of the debentures, as follows:

    The Conversion Price per share shall be the lesser of (i) seventy-five (75%)
    of the average of the three  lowest  closing bid prices for the Common Stock
    on the NASD OTC Bulletin  Board,  NASDAQ  SmallCap  Market,  NASDAQ National
    Market  System,   American  Stock  Exchange,  or  New  York  Stock  Exchange
    (whichever of the foregoing is at the time the principal trading exchange or
    market  for the  Common  Stock,  the  "Principal  Market"),  or  such  other
    principal  market or  exchange  where the Common  Stock is listed or traded,
    during the thirty (30)  trading  days prior to buy not  including  the issue
    date of the Note  ("Maximum  Base  Price");  and (ii) eighty  percent  (80%)
    percent of the average of the three lowest closing bid prices for the Common
    Stock  on the  Principal  Market,  or on any  securities  exchange  or other
    securities  market on which the Common Stock is then being listed or traded,
    during the ninety (90) trading days  immediately  prior to but not including
    the Conversion Date.

The issuance of 21,000,000 shares was based on a conversion rate of $.001482 for
a total dollar  amount of $31,122.  This was  acceptable  to both parties and is
consistent with valuation and disclosure of other similar  transactions in prior
periods.

ITEM 3, CONTROLS AND PROCEDURES, PAGE 10

    7.  You  disclose  that  your  controls  and   procedures   are  of  limited
        effectiveness.  Under Item 307 to  Regulation  S-B you should  express a
        clear and  unequivocal  opinion  about the  effectiveness  of disclosure
        controls and procedures. That is, you may state that disclosure controls
        and procedures are effective or you may state that  disclosure  controls
        and procedures are not effective. If you conclude that such controls and
        procedures  are  not  effective  you  should  also  provide  appropriate
        explanation.

    Response: The following is the new beginning of Item 3.
    ---------

<PAGE>

Securities and Exchange Commission
October 26, 2005
Page 6 of 6

                         ITEM 3. CONTROLS AND PROCEDURES

EVALUATION OF CONTROLS AND PROCEDURES

Under the supervision and with the  participation  of our management,  including
our Chief  Executive  Officer ("CEO") and Chief Financial  Officer  ("CFO"),  we
evaluated  the  effectiveness  of the design  and  operation  of our  disclosure
controls  and  procedures  (as defined in Rule  13a-15(e)  and  15d-15(e) of the
Exchange Act as of the end of the period covered by this report, June 30, 2005).
Based  upon  that  evaluation,  the CEO and CFO  concluded  that  the  Company's
disclosure controls and procedures were effective.

    8.  We see that the Chief  Executive  Officer  and Chief  Financial  Officer
        evaluated disclosure controls and procedures as of a date within 90 days
        before the filing  date of the  quarterly  report.  Amend to  disclosure
        management's   conclusion  regarding  the  effectiveness  of  disclosure
        controls  and  procedures  as of the end of the  period  covered  by the
        quarterly  report.  Refer to Item 307 of Regulation S-B and Part II.F of
        "Management's  Reports on Internal Control Over Financial  Reporting and
        Certification of Disclosure in Exchange Act Periodic  Reports"  (Release
        No. 33-8238).

    Response: See response to Comment #7.
    ---------

                                  *************

      We appreciate your timely consideration of these matters in your review of
the filing  referenced  above. If you or others have any questions or would like
additional information, please contact me at 212-930-9700.

                                           Very truly yours,

                                           /s/ THOMAS A. ROSE
                                           ------------------
                                           Thomas A. Rose

cc: Mr. John Cousins,
    Chief Financial Officer

<PAGE>

EXHIBIT A

--------------------------------------------------------------------------------
                        ADVANCED OPTICS ELECTRONICS, INC.
                          (A Development Stage Company)
                            STATEMENTS OF CASH FLOWS
    FOR THE SIX MONTH PERIODS ENDED JUNE 30, 2005 AND 2004 AND FOR THE PERIOD
               FROM MAY 22, 1996 (INCEPTION) THROUGH JUNE 30, 2005
                                   (Unaudited)
--------------------------------------------------------------------------------
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                                                                                                                     May 22, 1996
                                                                                                                      (Inception)
                                                                                                                        Through