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SEC Company Response from BIOMODA — Feb 4, 2005

BIOMODA INC/NM (CIK 0001058767)
Date: Feb. 4, 2005 · CIK: 0001058767 · Accession: 0001185185-05-000062

AI Filing Summary & Sentiment

File numbers found in text: 333-90738

Referenced dates: January 31, 2005

Date
February 4, 2005
Author
President
Form
CORRESP
Company
BIOMODA INC/NM (CIK 0001058767)

Letter

Re: Biomoda, Inc. Registration Statement on Form SB-2 Post-Effective Amendment No. 1 to Form SB-2 File No. 333-90738, filed January 13, 2005

BIOMODA, INC. 8301 Washington NE, Suite 5 Albuquerque, New Mexico 87113 Phone: (505) 821-0875

February 4, 2005

VIA EDGAR AND FEDERAL EXPRESS -----------------------------

Securities and Exchange Commission 450 Fifth Street, N.W. Washington, DC 20549

Attn: Jeffrey Riedler, Esq., Assistant Director Division of Corporation Finance

Anne Nguyen, Esq.

Ladies and Gentlemen:

The following responses address the comments of the reviewing Staff of the Commission as set forth in a comment letter dated January 31, 2005 (the "Comment Letter") relating to the Post-Effective Amendment No. 1 to the Registration Statement on Form SB-2 (the "Registration Statement") of Biomoda, Inc. (the "Company").

Pursuant to conversations between the Staff and our counsel, we are filing herewith Post-Effective Amendment No. 2 to the Company's Registration Statement to remove any reference to the additional 5 million shares of common stock we attempted to register on Post-Effective Amendment No. 2. Furthermore, we are filing today a new registration statement on Form SB-2MEF pursuant to Rule 462(b) to register an additional 1 million shares of common stock in this offering, which is not greater than 20% of the offering price.

We trust that the foregoing appropriately addresses the issues raised by your recent Letter of Comment. Thank you in advance for your prompt review and assistance.

Very truly yours,
/S/ JOHN J. COUSINS
-------------------
John J. Cousins
President

Show Raw Text
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<FILENAME>filename1.txt
<TEXT>

                                  BIOMODA, INC.
                           8301 Washington NE, Suite 5
                          Albuquerque, New Mexico 87113
                              Phone: (505) 821-0875

                                                February 4, 2005

VIA EDGAR AND FEDERAL EXPRESS
-----------------------------

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC  20549

         Attn:    Jeffrey Riedler, Esq., Assistant Director
                  Division of Corporation Finance

                  Anne Nguyen, Esq.

         Re:      Biomoda, Inc.
                  Registration Statement on Form SB-2
                  Post-Effective Amendment No. 1 to Form SB-2
                  File No. 333-90738, filed January 13, 2005

Ladies and Gentlemen:

     The following  responses address the comments of the reviewing Staff of the
Commission as set forth in a comment letter dated January 31, 2005 (the "Comment
Letter")  relating to the  Post-Effective  Amendment  No. 1 to the  Registration
Statement on Form SB-2 (the  "Registration  Statement")  of Biomoda,  Inc.  (the
"Company").

     Pursuant to conversations  between the Staff and our counsel, we are filing
herewith Post-Effective  Amendment No. 2 to the Company's Registration Statement
to remove any  reference to the  additional 5 million  shares of common stock we
attempted to register on  Post-Effective  Amendment No. 2.  Furthermore,  we are
filing  today a new  registration  statement  on Form  SB-2MEF  pursuant to Rule
462(b)  to  register  an  additional  1 million  shares of common  stock in this
offering, which is not greater than 20% of the offering price.

     We trust that the  foregoing  appropriately  addresses the issues raised by
your recent  Letter of Comment.  Thank you in advance for your prompt review and
assistance.

                                                       Very truly yours,

                                                       /S/ JOHN J. COUSINS
                                                       -------------------
                                                       John J. Cousins
                                                       President

</TEXT>
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