SecProbe.io

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Mail Stop 6010

      September 9, 2005

Mr. Lindsay Semple
Chief Executive Officer & Acting Chief Financial Officer
Global Precision Medical Inc.
#536 1489 Marine Drive
West Vancouver, BC, Canada V7T 1B8

	RE:	Global Precision Medical Inc.
		Form 10-KSB for the fiscal year ended December 31, 2004
		Filed July 21, 2005
		File No. 0-30330

Dear Mr. Semple:

      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
information so we may better understand your disclosure.  After
reviewing this information, we may 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.

Form 10-KSB for the period ending December 31, 2004

Report of Independent Registered Accounting Firm, page 15

1. We note in the audit report that the current auditor refers to
and
is relying on the report of the predecessor auditor for the
development stage period from August 24, 1990 (inception) through
to
December 31, 2002.  Please amend to include the report of the
predecessor auditor.  Refer to Item 310, Note 2 of Regulation S-B
and
Rule 2-05 of Regulation S-X.  Also, note the audit report
requested
should reference "the standards of the Public Company Accounting
Oversight Board (United States)" rather than GAAS.  This revision
is
required to comply with PCAOB Auditing Standard No. 1 since the
audit
report will be reissued after May 24, 2004.

2. We note your audit report was signed by BDO Dunwoody LLP, an
audit
firm registered with the PCAOB and based in Vancouver, Canada.  In
accordance with Article 2 of Regulation S-X, we believe that the
audit report of a registrant (that is not a foreign private
issuer)
should ordinarily be rendered by an auditor licensed in the United
States. Further guidance may be found in Section 5.K of
"International Reporting and Disclosure Issues in the Division of
Corporation Finance" on the Commission`s website at:
http://www.sec.gov/divisions/corpfin/internatl/cfirdissues1104.htm
#P4
42_69217.  Please tell us why you selected an auditor licensed
outside of the United States to audit your financial statements,
in
light of the fact that you were incorporated in Wyoming. We see
you
indicate in the filing that all the assets of the company are
located
in Canada.  Tell us where the audit was physically performed.
Please
note that it is your responsibility to provide financial
statements
audited by an auditor who meets the requirements of Rule 2-01(a)
of
Regulation S-X. Please tell us how you determined that you meet
the
requirements of Rule 2-01(a) of Regulation S-X. Also, please tell
us
what consideration you gave to Wyoming state laws governing audits
of
Wyoming companies performed by foreign auditors.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comments and provides any requested information.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

	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
Exchange Act of 1934 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.

	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 filings;

* staff comments or changes to disclosure in response to staff
comments 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.

      You may contact Dennis Hult, Staff Accountant, at (202) 551-
3618 or myself if you have questions regarding comments on the
financial statements and related matters.  Please contact me at
(202)
551-3603 with any other questions.  In this regard, do not
hesitate
to contact Angela J. Crane, Accounting Branch Chief, at (202) 551-
3554.

								Sincerely,

								Jay Webb
								Reviewing Accountant

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Lindsay Semple
Global Precision Medical Inc.
September 9, 2005
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