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CORRESP
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      Response to Sec Comments

    POWELL
      GOLDSTEIN, LLP

    ONE
      ATLANTIC CENTER

    FOURTEENTH
      FLOOR

    1201
      WEST PEACHTREE STREET, NW

    ATLANTA,
      GA 30309-3488

    TEL:
      404-572-6600

    FAX:
      404-572-6999

    WWW.POGOLAW.COM

    July
      21,
      2005

    Via
      EDGAR and Overnight Delivery

    For
      Commission Use Only

    Larry
      Spirgel

    Division
      of Corporation Finance

    United
      States Securities and Exchange Commission

    450
      Fifth
      Street, N.W.

    Washington,
      D.C. 20549-0303

              Re:

              Health
                Discovery Corporation

              Form
                10-KSB for the fiscal year ended December 31, 2004

              Form
                10-QSB for the period ended March 31, 2005

              File
                No. 333-62216

    Dear
      Mr.
      Spirgel:

    Thank
      you
      for your comment letter, dated July
      7,
      2005, issued by the staff of the Division of Corporation Finance with respect
      to
      the Forms 10-KSB and 10-QSB referenced above with respect to Health Discovery
      Corporation (the “Company”). On behalf of the Company, our client, we have
      prepared this reply to the comment letter.

    For
      your
      convenience, we have copied each comment into this letter first and responded
      to
      each one in sequence.

    Form
      10-KSB for the year ended December 31, 2004

    Comment
      1:

    Clyde
      Bailey’s letter dated May 11, 2005 to us indicated that they have withdrawn
      their consent included in the recent Form SB-2 filed by you. Please ask your
      auditors-Clyde Bailey to confirm us directly, whether they have not withdrawn
      their report included in the Form 10-KSB for the year ended December 31,
      2004.

    Response
      1:

    Until
      receipt of your letter, dated July 7, 2005, the Company was unaware of any
      indication that Clyde Bailey, P.C. ("Bailey") had withdrawn its consent to
      the
      inclusion of its report in the SB-2, which it had given prior to the Company's
      filing of the SB-2. At
      that
      time, the Company had not received a copy of the letter sent to you or any
      other
      similar communication from Bailey. Unfortunately, due to Mr. Clyde Bailey's
      travel schedule, the Company was unable to confirm until July 12, 2005, the
      facts set out in your letter to the Company -- that Bailey had withdrawn its
      consent to the SB-2. Upon confirming these facts with Bailey, the Company filed
      a report on Form 8-K, disclosing the change and included as Exhibit 16.1 a
      letter executed by Bailey to you confirming the accuracy of the disclosure
      contained in the filing. The Company will engage an independent auditing firm
      to
      re-audit the affected periods, and upon the completion of the re-audit, the
      Company will file an amendment to
      the
      Company’s SB-2. The Company will not seek to have the SB-2 declared effective
      until such amendment has been filed.

    Form
      10-QSB for the period ended March 31, 2005

    Additional
      Funding Requirement, page 7

    Comment
      2:

    You
      indicate that you have sufficient cash to continue operations through August,
      2005 based on your current cash flows. Please tell us what consideration was
      given to the requirements of Section 607.02 of the Financial Reporting
      Codification which requires that due to your financial difficulties and in
      absence of any viable plan to generate sufficient cash to support the operations
      during the twelve month period following the date of the financial statements,
      the financial statements should be prepared on the liquidation basis rather
      than
      on the going concern basis.

    Response
      2:

    The
      Company's two-pronged plan described in the 10-QSB to have sufficient cash
      to
      support operations on a going-forward basis was comprised of generating revenue
      through licensing the Company's significant patent portfolio or providing
      services related to those patents and obtaining additional equity or debt
      financing. The Company has been and continues to be in meaningful discussions,
      which if successful, will result in significant revenue to the Company.
      Additionally, since the filing of the 10-QSB, the Company secured $1,935,000
      through the private sale to accredited investors of shares of Company common
      stock, which together with the Company's existing cash will be sufficient to
      support the Company's operations through February, 2006. In future filings,
      the
      Company will expand its discussion of its plan to generate additional cash
      to
      support operations or to raise additional funds, and, to the extent that the
      Company's available cash and anticipated revenues will not be sufficient to
      support operations for the twelve-month period following the date of the
      financial statements, will include its financial statements prepared on a
      liquidation basis rather than on the going concern basis.

    We
      trust
      this response has addressed your concerns. Please do not hesitate to let us
      know
      any additional questions or comments that the staff may have. Thank
      you.

              Very
                truly yours,

              /s/
                Helen Zalik

              Helen
                Zalik

              For
                Powell Goldstein LLP

            cc:

              Stephen
                D. Barnhill

                Robert
                  S. Braswell

                Todd
                  Wade, Esq.