SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 03-09

December 4, 2004

Mr. Armand Dauplaise
President, Chief Executive Officer and Chief Financial Officer
Bio-One Corporation
1630 Winter Springs Boulevard
Winter Springs, FL 32708

Re:	Bio-One Corporation
      Form 8-K filed December 3, 2004
      File No. 000-31889

Dear Mr. Dauplaise:

      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 us at the telephone numbers
listed
at the end of this letter.

1. While we noted that the former accountant resigned, please
revise
your filing to specifically state whether the decision to change
accountants was recommended or approved by the board of directors
or
an audit or similar committee of the board of directors, as
required
by Item 304(a)(1)(iii) of Regulation S-K.

2. In providing the disclosures contemplated by Item 304(a)(1)(iv)
and (v) of Regulation S-K, please revise your filing to extent
"the
subsequent interim period" through the date of the former
accountant
resigned, as it is unclear whether disagreements and reportable
events occurred subsequent to September 30, 2004 but prior to the
resignation.

3. Please file a letter from the former accountant addressing the
revised disclosures.

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 filing;

* 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 file your supplemental response and amendment via
EDGAR
in response to these comments within 5 business days of the date
of
this letter.  Please note that if you require longer than 5
business
days to respond, you should contact the staff immediately to
request
additional time.  Direct any questions regarding the above to me
at
(202) 942-2902.

							Sincerely,

							Oscar M. Young, Jr.
							Senior Accountant
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Mr. Armand Dauplaise
Bio-One Corporation
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