SecProbe.io

November 24, 2010

William F. Donovan, M.D. Chief Executive Officer Spine Pain Management, Inc. 5225 Katy Freeway
Suite 600
Houston, Texas 77007
Re: Spine Pain Management, Inc.  Form 10-K for the Fiscal Year Ended December 31, 2009
Filed March 31, 2010 Form 10-Q for the Quarterly Period ended June 30, 2010 Filed August 16, 2010 File No. 000-27407
 Dear Dr. Donovan:
 We have reviewed your September 29, 2010 response to our September 21, 2010 letter
and have the following comments.  In our comment s, we ask you to provide us with information
so we may better understand your disclosure.
 Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  Where a comment requests you to revise disclosu re, the information you provide s hould show us what the revised
disclosure will look like and identify the annual or quarterly filing, as applicable, in which you
intend to first include it.  If you do not be lieve a comment applies to your facts and
circumstances, please tell us why in your res ponse.  Please furnish us a letter on EDGAR under
the form type label CORRESP that keys  your responses to our comments.
 After reviewing the information provided, we may have additional comments and/or
request that you amend your filing.               Form 10-K for the Fiscal Year Ended December 31, 2009

Item 7.  Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Policies
 Revenue Recognition, page 20

1. Refer to your response to Comment One.  You state that typically the defendant in the
accident case pays the patient’s bill upon sett lement or final judgment of the accident

William F. Donovan, M.D.
Spine Pain Management, Inc.
 November 24, 2010  Page 2

case.  In order to recognize re venue, please tell us how you c oncluded that 1) persuasive
evidence of an arrangement existed between al l of the parties and 2) collectability was
reasonably assured.
2. Further, you have currently estimated the av erage discount on all cu rrent cases will be
45% based on historical case resolution expe rience.  In addition you appear to have
collected only $32,006 of receivables in the Company’s entire history.  Please tell us what historical case resoluti on supported your 45% discount.

3. Refer to your proposed statement of operations  presentation presented in Exhibit 2 of
your response.  Please tell us what gross re venue represents and why presenting it is
meaningful to understanding your results of operations.  Otherwise, please revise your presentation to only present ne t revenue, which was $540,505 in 2009.

Please contact James Peklenk, Staff Account ant, at (202) 551-3661 or Joel Parker,
Accounting Branch Chief, at (202) 551-3651 if you have any questions regarding the comments.
In this regard, do not hesitate to contact me, at (202) 551-3679.

Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant