SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>novabioletter1.txt
<DESCRIPTION>COMMENT LETTER ON ITEM 4, FORM 8-K; SENT 9/3/04; C. LUCKEY
<TEXT>

 September 3, 2004

Mail Stop 0409

VIA U.S. MAIL AND FAX (770) 650-0411

Mr. Tim Moses
Chief Operating Officer
Nova Biogenetics, Inc.
8601 Dunwoody Place
Suite 338
Atlanta, GA  30350

Re:	Item 4 Form 8-K filed September 2, 2004

Dear Mr. Moses:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your documents in response to
these comments.  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 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.

	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 on any other aspect
of our review.  Feel free to call me at the telephone number listed
at the end of this letter.

1. Amend the report to include all of the information required by
Item 304 of Regulation S-B.
2. State whether the board of directors recommended or approved the
decision to change accountants.
3. In addition, Item 304(a)(1)(ii) of Regulation S-B requires a
statement whether the accountants` report on the financial statements
for either of the past two years contained an adverse opinion or a
disclaimer of opinion or was qualified or modified as to uncertainty,
audit scope or accounting principles; and a description of the nature
of each such adverse opinion, disclaimer of opinion, modification or
qualification.  This would include disclosure of uncertainty
regarding the ability to continue as a going concern in the
accountant`s report.
4. The disclosure should also state whether during the registrant`s
two most recent fiscal years and any subsequent interim period
through the date of resignation, declination or dismissal there were
any disagreements with the former accountant on any matter of
accounting principles or practices, financial statement disclosure,
or auditing scope or procedure, which disagreement(s), if not
resolved to the satisfaction of the former accountant, would have
caused it to make reference to the subject matter of the
disagreement(s) in connection with its reports.  In the event of
disagreement(s) and/or reportable event(s), provide the specific
disclosures required by Item 304(a)(1)(iv) of Regulation S-B.
5. Please comply with the requirements of Regulation S-B Item 304
(a)(2).  In making any disclosures about consultations with your new
accountants, please ensure you disclose any consultations up through
the date of engagement.
6. To the extent that you make changes to the Form 8-K to comply with
our comments, please obtain and file an updated Exhibit 16 letter
from the former accountants stating whether the accountant agrees
with the statements made in your revised Form 8-K.

We urge all persons who are responsible for the accuracy and adequacy
of the disclosure in the filings reviewed by the staff to be certain
that they have provided all information investors require.  Since the
company and its management are in possession of all facts relating to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement has
access to all information you provide to the staff of the Division of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

Please provide the supplemental information requested above within 10
business days from the date of this letter.  The supplemental
information should be filed as correspondence on EDGAR.  The
amendment requested above should be filed as promptly as possible and
should be reviewed by the newly engaged accountants before filing
with the Commission.

Direct any questions regarding the above to me at (202) 942-1975.

							Sincerely,

							Cicely D. Luckey
Senior Staff Accountant
Nova Biogenetics, Inc.
September 3, 2004

Page 1

</TEXT>
</DOCUMENT>