SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 3561
								August 11, 2005
Mr. Edward Alexander
Chief Executive Officer
Proton Laboratories, Inc.
1135 Atlantic Avenue
Suite 101
Alameda, CA  94501

      Re:	Proton Laboratories, Inc.
		Form 10-KSB/A for the Fiscal Year Ended December 31,
2004
		File No. 0-31883

Dear Mr. Alexander:

      We have reviewed your response letter dated August 4, 2005
and
have the following comment.  We have limited our review only to
your
financial statements and related disclosures and do not intend to
expand our review to other portions of your document.  We think
you
should amend your in response to this 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 explanations.

	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/A for the Fiscal Year Ended December 31, 2004

Explanatory Note, cover page

1. We have reviewed your amended Form 10-KSB for the year ended
December 31, 2004 including the explanatory paragraph explaining
that
your amendment was in response to our comment letter.  Please re-
amend your document to remove your reference to our comment letter
in
your explanatory note as the basis for your revisions.  We
generally
would expect an amendment to be based upon the correct application
of
generally accepted accounting principles in the United States and
/
or SEC Rules, and not as a result of our comment letter.  Please
specify why you have amended your document and which sections of
the
document you revised.

* * * * *

       Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please understand
that
we may have additional comments after reviewing your responses to
our
comments.

	You may contact Scott Ruggiero at (202) 551-3331 if you have
questions regarding this comment on the financial statements and
related matters.  Please contact me at (202) 551-3716 with any
other
questions.

Sincerely,

William Choi
Branch Chief

Mr. Edward Alexander
Proton Laboratories, Inc.
August 11, 2005
Page 1

</TEXT>
</DOCUMENT>