SecProbe.io

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Mail Stop 7010

      August 12, 2005

via U.S. mail and facsimile to (604) 648-8963

Ms. Nora Coccaro
Chief Executive Officer and Chief Financial Officer
Healthbridge, Inc.
1066 West Hastings Street, Suite 2610
Vancouver, British Columbia  Canada  V6E 3X2

RE:	Healthbridge, Inc.
Form 10-KSB for Fiscal Year Ended December 31, 2004
		Filed April 7, 2005
		File No. 000-30377

Dear Ms. Coccaro:

		We have reviewed your response letter dated August 4,
2005
to our letter dated July 18, 2005 and have the following comments.
If you disagree with a comment, 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 supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

Note 1 - Organization and Summary of Significant Accounting
Policies,
Intangible Assets, page F-13

1. We note your response to comment 1 in our letter dated July 18,
2005 that you have classified your patents as intangible assets
with
definite lives since acquisition in early 2002.  However, it
remains
unclear why you have not and continue to not amortize the patents
over the ten year estimated useful life, if you have "always
maintained" the patents have a definite life.  Please tell us your
rationale for not amortizing the patents to date, including the
authoritative literature upon which you are relying to support
your
accounting.  Otherwise, please amend your Form 10-KSB for the
fiscal
year ended December 31, 2004 and include the following changes:
* Request your auditor include an explanatory paragraph in the
reissued audit opinion.  Note that your auditor should consider
the
appropriate date(s) for the audit opinion.
* Restate your consolidated financial statements, reflecting the
amortization of your patents over a ten year period since the date
of
acquisition.
* Include footnote disclosure that fully complies with paragraphs
36
and 37 of APB 20.
* Fully update all affected portions of the Form 10-KSB, including
MD&A, selected financial data, etc.
* Update your Item 8A disclosures to include the following:
o A discussion of the restatement and the facts and circumstances
surrounding it;
o How the restatement impacted your CEO and CFO`s original
conclusions regarding the effectiveness of your disclosure
controls
and procedures; and
o Anticipated changes to disclosure controls and procedures and/or
internal controls over financial reporting to prevent future
misstatements of a similar nature.
   Refer to Items 307 and 308(c) of Regulation S-B.
* Amend your Form 10-QSB for the fiscal quarter ended March 31,
2005
to reflect the necessary changes to your financial statements and
related disclosures.
* Update your certifications included in all amended Forms.

	If you conclude that your consolidated financial statements
are
to be restated and that your prior flings should not be relied
upon
due to an error, please be advised that you are required to
disclose
the information listed under Item 4.02(a) of Form 8-K within four
days of your conclusion.

2. We also note from your response to comment 1 in our letter
dated
July 18, 2005 that there have been no sales of your waste disposal
units since the first quarter of 2004 as of today.  As such,
please
tell us the dates of the impairment tests you performed during
fiscal
years 2004 and 2005.  Please provide us with your most recent
discounted cash flow analysis that supports the recoverability of
this asset.  Your analysis should provide us with sufficiently
detailed information to allow us to understand the material
assumptions you have made and why you believe those assumptions
are
reasonable.  If you continue to believe that your patents are not
impaired, please revise your disclosure under critical accounting
policies to provide detailed disclosure of the facts that support
your belief your patents are not impaired in light of the fact
that
you have been unsuccessful in selling additional products since
the
first quarter of fiscal year 2004.

*   *   *   *

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

		If you have any questions regarding these comments,
please
direct them to Ryan Rohn, Staff Accountant, at (202) 551-3739 or,
in
his absence, to Tracey Houser, Staff Accountant, at (202) 551-
3736,
or to the undersigned at (202) 551-3255.

							Sincerely,

							Nili Shah
							Accounting Branch Chief
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Ms. Nora Coccaro
Healthbridge, Inc.
August 12, 2005
Page 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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