SecProbe.io

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                               HADDAN & ZEPFEL LLP
                       500 Newport Center Drive, Suite 580
                             Newport Beach, CA 92660
                                 (949) 706-6000
                           (949) 706-6060 (facsimile)
                          e-mail: rjz@haddanzepfel.com

                                  May 25, 2005

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

         Attn: Jay Webb
               Mail Stop 03-06

                             Re: Eye Dynamics, Inc.
                Form 10-KSB for the Year Ended December 31, 2004
                               (File No. 0--27857)

Dear Sirs:

         This is in response to your letter of May 12, 2005 concerning the
Annual Report on Form 10-KSB of Eye Dynamics, Inc. (the "Company") for the year
ended December 31, 2004.

         The responses are set forth in the order of your letter:

Item 8A-Controls and Procedures
-------------------------------

         1. The Company plans to revise future filings, commencing with the
Quarterly Report on Form 10-QSB for the period of three months ended June 30,
2005, to state that the Company's controls and procedures are designed to
provide reasonable assurance of achieving their objectives, and that the
principal executive officer and principal financial officer concluded that the
disclosure controls and procedures are effective at that reasonable assurance
level. In addition, we will delete the reference to the level of assurance of
the disclosure controls and procedures.

Note 1- Nature of Business and Critical Accounting Policies--Page F-6
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Revenue Recognition--Page F-6
-----------------------------

         2. The Company plans to revise Note 1 to its financial statements in
future filings to read substantially as follows:

         The Company distributes products through special instrument dealers
         that buy inventory from the Company and then resell products to end
         users. The Company has also supplied a modified version of its
         Infrared/Video ENG System to two distributors on a private label basis.
         Revenue from these distributors is recognized when products are shipped
         and accepted by the end users. Based on the Company's historical
         experience, no provision has been established for estimated product
         returns and allowances. Commission cost, price discounts and other
         sales incentives are accrued and charged to cost of sales when revenue
         from these distributors is recognized.

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Securities and Exchange Commission
May 25, 2005
Page 2

3. Property and Equipment--Page F-8
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         The Company believes that its existing note is adequate, and doesn't
plan to revise it, for the following reasons.

         Impairment detection products (aka SafetyScope(TM)) are included in
inventory. The Company has been test marketing the products and has sold a few
units in various locales. Currently, independent sales representatives are being
recruited to achieve geographic distribution coverage over the United States.
However, implementation of a full marketing plan is contingent on receipt of
additional working capital. The preferred pricing model is the future strategy
if the Company commences to market the products on a large scale. For the year
ended December 31, 2004 and prior years, the Company had not yet implemented
this pricing model for the products.

         In future filings the Company plans to address and clarify the issues
of capitalizing the appropriate inventory assets to depreciate them over a three
year period.

Note 8--Income Taxes-Page F-12
------------------------------

         The Company plans to include a reconciliation of the accounting for the
difference between income taxes computed at the federal statutory rate and the
reported provision for income taxes (benefits) in future filings.

         On behalf of the Company, we confirm its understanding that (i) the
Company is responsible for the adequacy and accuracy of the disclosure in its
filings, (ii) 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 (iii) 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.

                                           Very truly yours,

                                           /s/ Robert J. Zepfel

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