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      GARY
        CURTIS CANNON

      ATTORNEY
        AT LAW

      12341
        Briardale Way

      San
        Diego, CA 92128-5212

      ____________________

      Telephone
        (858) 391-9083 Facsimile (858) 391-9084

      email:
        garycurtiscannon@lawyer.com

      December
        9, 2005

      Jeffrey
        Riedler

      Assistant
        Director

      Division
        of Corporate Finance

      United
        States Securities and Exchange Commission

      Washington,
        D.C. 20549

              Re:

                CryoPort,
                  Inc.

      Form
        10-SB

      Filed
        October 20, 2005

      File
        No.
        0-51578

      Dear
        Mr.
        Riedler,

      As
        General Counsel for CryoPort, Inc. (CryoPort), I have been requested by Peter
        Berry CryoPort’ s Chief Executive Officer to respond on behalf of the Company to
        the SEC comments letter of November 16, 2005 regarding CryoPort’s Form 10-SB
        filing. It is CryoPort’s intent to file an Amended Form 10-SB once we have had a
        review and acceptance of the Company’s responses. To that end, I have provided
        individual responses to the comments below. They should be read in conjunction
        not only with the comments letter, but the initial Form 10-SB filing and
        the
        Form 10-SB/A draft enclosed with this letter. Once the SEC is satisfied with
        the
        proposed changes and or the responses, the Company will make the electronic
        filing. The responses are as follows:

      Comment
        1:

      It
        is the
        intent of CryoPort to complete the Registration before the 60 days.

      Comment
        2:

      The
        following information per SB Regulation 101 (b)(11) has been added as a final
        paragraph in the “Manufacturing” section on page 19: “The Company’s
        manufacturing process uses non- hazardous cleaning solutions which are provided
        and disposed of by an EPA approved supplier. EPA compliance costs for the
        Company are therefore negligible.” (See Draft Form 10-SB/A).

        The
          following information per SB Regulation 101(b)(12) has been added in paragraph
          4
          under the “Overview” section on page 4: “The Company currently occupies
          approximately 8,000

      Jeffrey
        Riedler, Assistant Director

      United
        States Security and Exchange Commission

      December
        9, 2005

      Page
        2

      square
        feet of manufacturing and office space in Brea, California and have five
        full-time employees
        and three full-time and eight part-time consultants.” (See Draft Form
        10-SB/A).

      Comment
        3: In response to SEC comment #3, CryoPort has added additional information
        to
        the first paragraph in the “Overview” section on page 4, to make a more
        straightforward explanation of what a dry cryogenic shipper is. (See Draft
        Form
        10-SB/A).

      Comment
        4: In response to comment #4, the Company has added additional information
        in
        paragraph 2 in the “Overview” section on page 4 to further explain the
        differences of reusable and disposable shippers and the current development
        status of the disposable shippers. (See Draft Form 10-SB/A).

      Comment
        5: In response to comment #5, the Company has inserted as the last paragraph
        in
        the “Overview” section on page 4, the following: “As reported in the Report of
        Independent Registered Public Accountant on the Company’s March 31, 2005 and
        2004 financial statements, the Company has incurred recurring losses from
        operations and has a stockholders’ deficit. These factors, among others raise
        substantial doubt about the Company’s ability to continue as a going concern.
        See page 26, “Management’s Discussion and Analysis or Plan of Operation” for
        further discussion.” (See Draft Form 10-SB/A).

      Comment
        6: In response to comment #6, the Company has inserted into the second paragraph
        under the “History” section on Page 5, the following: “The exchange price was
        reached through discussions between CryoPort Systems, Inc.’s board of directors
        and stockholders, and G.T.5-Limited’s board of directors and major stockholders,
        taking into account supply and demand factors as well as the historical share
        prices to non-insiders of each company. The acquisition was a transaction
        involving the cashless exchange of shares only.” (See Draft Form
        10-SB/A).

      Comment
        7: The Share Exchange Agreement was provided in the original filing as Exhibit
        10.1.1.

      Comment
        8: In response to comment #8 , the Company has inserted at the end of the
        paragraph in the “Smaller,
        More Efficient Packaging.”
        Section
        on Page 9: “CryoPort currently manufactures its reusable shipper with an
        approximate liquid nitrogen volume of five liters. The Company’s future intended
        products will be a range of shippers with liquid nitrogen capacities from
        approximately one to five liters in size.” (See Draft Form
        10-SB/A).

      Comment
        9: In response to comment #9, the Company has inserted at the end of the
        first
        paragraph in the section “Emphasis
        on Decreasing Costs and System Simplification.”
        on Page
        9 -“The current price of CryoPort’s reusable shippers range from $685 to $1,095.
        The price range for the proposed disposable/one way shippers when developed
        is
        initially expected to range from $50 to $175 per use depending on size.” (See
        Draft Form 10-SB/A).

      Jeffrey
        Riedler, Assistant Director

      United
        States Security and Exchange Commission

      December
        9, 2005

      Page
        3

      Comment
        10: In response to comment #10, the Company has revised the second paragraph
        in
        the section “Emphasis
        on Decreasing Cost and System Simplification.”
        As well
        as the third paragraph on page 8 in section “Industry Overview” to clarify the
        product’s hold time and provide competitive hold time comparison. (See Draft
        Form 10-SB/A).

      Comment
        11: In response to comment #11, the Company has only one sales and distribution
        agent for South America which accounts for 10% of annual sales. This information
        has been incorporated in the first paragraph of the section “Sales and
        Marketing” on Page 14. The details of the Company’s contract with its South
        American sales and distribution agent are confidential. Providing the contract
        as an exhibit or exposing the terms of the contract would create difficulties
        with other company agents and distributors, as well as customers and other
        market competitors. Therefore we are not including a copy of the contract
        as an
        exhibit.

      Comment
        12: In response to comment #12, the Company has inserted the requested
        information showing the sales breakdown by geographical area in the “Sales and
        Marketing” section on page 14. (See Draft Form 10-SB/A).

      Comment
        13: In response to comment #13, the Company has revised the paragraph in
        the
“Competition” section on page 17 to include the following: “Other competitive
        factors include the ability of the shipper to retain liquid nitrogen when
        placed
        in non-upright positions, the overall “leak-proffness” of the package which
        determines compliance with shipping regulations and the overall weight and
        volume of the package which determine shipping costs.” (See Draft Form
        10-SB/A).

      Comment
        14: In response to comment #14, the Company has revised the paragraph in
        the
“Research and Development” section on page 18 to included the following: “The
        Company’s principal research and development activities for the years 2004 and
        2005 have centered around the investigation of materials of construction
        for the
        products and packages with the view of identifying those materials that yield
        fabrication costs consistent with the concept of disposability. Prototypes
        of
        one version of a unit dose transport system were developed and preliminary
        designs of a second concept were completed. Other research and development
        effort was directed toward improvements to the liquid nitrogen retention
        system
        to render it more reliable in the general shipping environment.” (See Draft Form
        10-SB/A).

      Comment
        15: In response to comment #14, the Company has inserted a paragraph in the
        “Manufacturing” section on page 18 as follows: “Primary manufacturers include
        Spaulding Composites Company, Peterson Spinning and Stamping, Lydall Industrial
        Thermal Solutions, Ludwig, Inc., and Porex Porous Products Group. There are
        no
        specific agreements with any manufacturer nor are there any long term
        commitments to any. It is believed that any of the currently used manufacturers
        could be replaced within a short period of time as none have a proprietary
        component nor a substantial capital investment specific to the Company’s
        products.”

      Jeffrey
        Riedler, Assistant Director

      United
        States Security and Exchange Commission

      December
        9, 2005

      Page
        4

      Comment
        16: In response to comment #16, the Company has inserted a chart on page
        19 in
        the “Proprietary Rights and Licensing” section which includes the requested
        information including issuance and expiration dates for patents and trademarks.
        Additionally, the Company has inserted information to describe the patents
        and
        trademarks in more detail as follows: “The technology covered by the above
        indicated patents refer to matters specific to the use of liquid nitrogen
        dewars
        relative to the shipment of biological materials. The concepts include those
        of

      disposability,
        package configuration details, liquid nitrogen retention systems, systems
        related to

      thermal
        performance, systems related to packaging integrity, and matters generally
        relevant to the containment of liquid nitrogen. Similarly, the trademarks
        mentioned relate to the cryogenic temperature shipping activity.” (See Draft
        Form 10-SB/A).

      Comments
        17 and 18: In response to comments #17 and #18, the Company has consolidated
        the
        original first four risk factors into a single risk factor and has eliminated
        any repetitive text in the “Risk Factors” section on pages 21 and 22. In
        addition, the Company has added subheadings to clarify each risk factor
        discussed. (See Draft Form 10-SB/A).

      Comment
        19: In response to comment #19, the Company has revised its statement in
        the
“Risk Factors” section on page 23 relating to if the Company is not able to
        compete effectively, to more clearly disclose the Company’s competitive
        situation. Harsco Corporation and Chart industries have been included as
        the two
        significant competitors. (See Draft Form 10-SB/A).

      Comment
        20: In response to comment #20, the Company, has revised its statement in
        the
“Risk Factors” section on page 24 in order to clearly identify the factors
        affecting the Company’s ability to attract and retain skilled personnel by
        inserting the following: “The ability to attract personnel to the Company’s
        vision depends both on the availability of skills and the ability of the
        Company
        to offer compensation and challenge compatible to career goals of potentially
        available individuals. The Company believes that the growth factors in the
        target markets are sufficient to attract the interest of well-qualified
        candidates for all positions as the need arises. To date, the Company has
        not
        experienced difficulties in attracting or retaining qualified personnel,
        however, there is no guarantee that there will be well-qualified candidates
        in
        the future to choose from.” (See Draft Form 10-SB/A).

      Comment
        21: In response to comment #21, the Company has inserted a statement in the
        “Risk Factors” section on page 25 relating to if the Company’s needs and ability
        to obtain patent and trademark protection, as follows: “The Company is not aware
        of any other company that is infringing any of the Company’s patents or
        trademarks nor does the Company believe that it is infringing on the patents
        or
        trademarks of any other person or organization.” See Draft Form
        10-SB/A).

      Comment
        22: In response to comment #22, the Company has inserted a statement in the
        “Risk Factors” section on Page 25 relating to if the Company experiences
        manufacturing delays or

      Jeffrey
        Riedler, Assistant Director

      United
        States Security and Exchange Commission

      December
        9, 2005

      Page
        5

      interruptions,
        as follows: “To date, the Company has not experienced any material delays to the
        point that its ability to adequately service customer needs has been
        compromised. As the business develops and quantity of production increases,
        it
        becomes more likely that such problems could arise.” (See Draft Form 10-SB/A).

      Comment
        23: In response to comment #23, the Company has made no revision to “Risk
        Factors” section relating to the Company’s governance by Penny Stock Regulations
        on page 24 due to the

      fact
        that
        the last trade and the current asked price for Company common stock, as of
        the
        date of the Company’s responses, was and is $4.90. This more current trade price
        was inserted in the subsequent “Risk Factors” section relating to effect on
        stock price from the sale of substantial shares on page 27. (See Draft Form
        10-SB/A).

      Comment
        24: In response to comment #24, the Company, on Page 28, has revised its
        statement in the “Liquidity and Capital Resources” - “Total assets” section to
        disclose the amount and source of research and development funding to include
        the following: “During the last quarter of the Company’s 2005 operations,
        funding of $991,875 was raised through a private placement offering of common
        stock under regulation D. These funds were raised to allow the Company to
        focus
        on accelerating the development and launch of its one-way product.” (See Draft
        Form 10-SB/A).

      Comment
        25: In response to comment #25, the Company has inserted information to update
        the Company’s current plans to launch the new product in the “Liquidity and
        Capital Resources” - “Total assets” section on page 28 as follows: “It is
        planned to introduce the single use/one-way products in limited quantities
        to
        selective customers during the first quarter of calendar year 2006. A broad
        launch to the general market will follow after feedback from this introductory
        distribution is received and customer demand is further understood. A higher
        volume demand is expected to develop as pharmaceutical products requiring
        cryogenic protection come to