SecProbe.io

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Mail Stop 6010

							July 5, 2005

Douglass T. Simpson
President and Chief Executive Officer
Corgenix Medical Corporation
12061 Tejon Street
Westminster, Colorado 80234

	Re:	Corgenix Medical Corporation
		Registration Statement on Form SB-2
		Filed June 24, 2005
		File No. 333-126115

		Form 10-KSB for the Year Ended June 30, 2004
		Filed October 13, 2004
		File No. 0-24541

Dear Mr. Simpson:

	We have limited our review of your filing to those issues we
have addressed in our comment.  Where indicated, we think you
should
revise your document in response to the comment.  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.

	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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-KSB

1. We note in Item 8A of your Form 10-KSB that the "Evaluation
Date"
for the CEO and CFO`s conclusion that the disclosure controls and
procedures are effective is "as of a date within ninety days
before
the filing date of this annual report."  Please be aware that Item
307 of Regulation S-B requires that the conclusion be as of the
end
of the period covered by the report.  Please file an amended Form
10-
KSB to revise the evaluation date.

*	*	*

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment decision.  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.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

* the company may not assert staff comments and the declaration of
effectiveness 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 connection with our review of
your
filing or in response to our comments on your filing.

	We will consider a written request for acceleration of the
effective date of the registration statement as confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

	We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

	Please contact Greg Belliston at (202) 551-3861 or me at
(202)
551-3715 with any questions.

								Sincerely,

								Jeffrey P. Riedler
								Assistant Director

cc:	Robert Attai, Esq.
	Otten, Johnson, Robinson, Neff & Ragonetti, P.C.
	950 Seventeenth Street, Suite 1600
	Denver, Colorado 80202
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Douglass T. Simpson
Corgenix Medical Corporation
July 5, 2005
Page 1

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