SecProbe.io

CORRESP
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        November
          10, 2005

        VIA
          EDGAR AND U.S. MAIL

        Ms.
          Angela J. Halac

        United
          States Securities and Exchange Commission

        Division
          of Corporate Finance

        Mail
          Stop
          3561

        Washington,
          D.C. 20549

                        RE:

                  Ultra
                    Pure Water Technologies, Inc.

                    Item
                      4.01 Form 8-K

                    Filed
                      August 1, 2005

                    File
                      No. 000-28267

        Dear
          Ms.
          Halac:

        This
          letter has been prepared in response to your request for Ultra Pure Water
          Technologies, Inc. (“UPWT”
          or the
“Company”)
          to
          respond to the comments of the United States Securities and Exchange Commission
          (the “SEC”
          or the
“Commission”)
          as
          memorialized in your August 10, 2005 letter to Daniel D. LeBlanc (the
“Comment
          Letter”)
          concerning the above-referenced Item 4.01 of Form 8-K (the “Form
          8-K”).

        Concurrently
          with the filing of this Response Letter, the Company is also filing an
          Amendment
          to the Form 8-K (the “Amended
          Form 8-K”),
          which
          Amended Form 8-K incorporates, as appropriate, the responses of the Company
          contained herein.

        The
          following are the Company’s responses to the Comment Letter, which responses
          follow a recitation of the relevant comment.

        Item
          4.01 of Form 8-K

                  COMMENT
                    1:

                  The
                    statement by the company that Rachlin Cohen & Holtz has been engaged
                    as your independent accountant implies that the company had a
                    previous
                    auditor. Item 304 of Regulation S-B describes the disclosure
                    requirements
                    of the Item 4.01 on Form 8-K. In order for the former accountants
                    to
                    submit to you the letter required by Item 304(a)(3) of Regulation
                    S-B, a
                    copy of the filing should be furnished to them as soon as possible,
                    but no
                    later than the date you file the Form 8-K with the Commission.
                    The
                    accountant’s letter should be filed with the Commission as an exhibit to
                    the 8-K when initially filed or as a subsequent amendment thereto
                    no later
                    than 10 days after the initial Form 8-K was filed.

                    RESPONSE
                      1:

                    UPWT
                      is formerly Hundred Mile Plus LTD., Inc. and VDO.com. In June
                      2001,
                      Crouch, Bierwolf & Chisholm, LLP (“Crouch”),
                      independent certified public accountants, previously engaged
                      as the
                      principal accountants to audit the financial statements of
                      VDO.com, Inc.,
                      resigned as auditors of VDO.com. The Board of Directors of
                      VDO.com
                      accepted, but did not recommend or approve Crouch’s resignation. The
                      Company disclosed the resignation of Crouch in the Form 8-K
                      filed with the
                      Commission on February 5, 2002 (File No.
                      000-28267).

                    In
                      June 2001, Zakheim, Roth & Co. LLP (“Zakheim”)
                      also resigned as an independent certified public accounting
                      firm for the
                      VDO.com. Zakheim resigned because it was not registered with
                      the
                      Commission and therefore it was unable to audit the VDO.com.
                      VDO.com’s
                      Board of Directors accepted, but did not recommend or approve,
                      Zackeim’s
                      resignation.

                  The
                    Company has revised the Amended Form 8-K to include the disclosure
                    requirements of Item 304 of Regulation S-B as requested by the
                    Commission.
                    The Amended Form 8-K also contains, as an exhibit thereto, the
                    letter from
                    Zakheim required by Item 304(a)(3) of Regulation
                    S-B.

        Should
          you have any questions concerning this Response Letter or the Amended Form
          8-K,
          please contact me at (337) 233-7317.

                Very
                  truly yours,

                  /s/
                    Daniel D. LeBlanc

                  Daniel
                    D. LeBlanc

                  President
                    and Chief Executive Officer

        cc: Clayton
          E. Parker, Esq., Kirkpatrick & Lockhart Nicholson Graham, LLP