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[CLEARANT, INC. LETTERHEAD]

April 20, 2005

BY EDGAR AND U.S. MAIL

Securities and Exchange Commission

Division of Corporate Finance

Office of Mergers and Acquisitions

450 Fifth Street, N.W.

Washington, D.C. 20549-0303

Attn: Mara L. Ransom, Special Counsel

    Re:

    Clearant, Inc.

Information Statement Pursuant to
Section 14(f) of the Securities

        Exchange Act of 1934 and Rule 14f-1 thereunder

    Filed April 1, 2005

    File Number 5-80638

Dear Ms. Ransom:

     In connection with your comments to the Information Statement Pursuant to Section 14(f) of the
Securities Exchange Act of 1934 and Rule 14f-1 thereunder filed by Clearant, Inc. (the “Company”)
on April 1, 2005, the Company acknowledges that

    •
    the Company is responsible for the adequacy and accuracy of the disclosures in
the filing;

    •
    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 defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the
United States.

    Respectfully yours,

CLEARANT, INC.

    By:
    /s/ DONALD J. LEWIS

    Donald J. Lewis

    Chief Financial Officer

[GREENBERG TRAURIG, LLP LETTERHEAD]

John C. Kirkland

Tel. 310.586.7786

Fax 310.586.0286

KirklandJ@gtlaw.com

April 20, 2005

BY EDGAR AND U.S. MAIL

Mara L. Ransom, Esq.

Special Counsel

Office of Mergers and Acquisitions

Division of Corporation Finance

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549-0303

    Re:

    Clearant, Inc.

    Information Statement Pursuant to
Section 14(f) of the Securities

        Exchange Act of 1934 and Rule 14f-1 thereunder

    Filed April 1, 2005

    File Number 5-80638

Dear Ms. Ransom:

By letter dated April 11, 2005 from the staff of the Securities and Exchange Commission (“Staff”),
the Staff made comments to the Information Statement Pursuant to Section 14(f) of the Securities
Exchange Act of 1934 and Rule 14f-1 thereunder filed by our client Clearant, Inc. (the “Company”)
on April 1, 2005. On behalf of the Company, we are responding to the comment letter in the
following numbered paragraphs, which correspond to the paragraph numbers in the comment letter.

Security Ownership of Certain Beneficial Owners and Management, page 5

    1.
    In the future, please note that the footnotes to the beneficial ownership table should
identify the natural person who controls, i.e., voting or investment power, the stock owned by
the entities listed in the table. See Exchange Act Rule 13d-3. For example, you should have
disclosed the natural person who controls the common

Mara L. Ransom, Esq.

April 20, 2005

Page 2

    stock owned by Biomedicine, L.P., Rock
Creek Partners II, Ltd., and Affinity Ventures III, L.P.

    RESPONSE. In the future, the footnotes to beneficial ownership tables will
identify the natural persons who control the stock owned by listed entities. The
Company’s proxy statement on Schedule 14A for its 2005 annual meeting of stockholders will
disclose the natural persons who control the common stock owned by Biomedicine, L.P., Rock
Creek Partners II, Ltd., and Affinity Ventures III, L.P.

    2.
    We note that some of your shareholders beneficially own greater than 5% of your common stock
as a result of the merger. Our records indicate, however, that none of these persons has
filed beneficial ownership reports on Schedule 13D or 13G pursuant to Sections 13(d) and 13(g)
of the Exchange Act of 1934 and Rule 13d-1. Please advise.

    RESPONSE. We note that Biomedicine, L.P., Rock Creek Partners II, Ltd., Terren S.
Peizer and Affinity Ventures III, L.P. have now filed Schedules 13G pursuant to section
13(g) of the Exchange Act of 1934 and Rule 13d-1.

Committees of the Board of Directors, page 7

    3.
    In the future, please revise to ensure that you have provided all of the information required
pursuant to Item 7(d) of Schedule 14A, including information regarding the lack of a
nominating committee and shareholder communications, or tell us why you do not believe
additional information is required. Note that even where the company does not have any
defined policy or procedures for the nomination of directors and shareholder recommendations,
provide the basis for the board’s apparent view that it is appropriate not to have a policy
regarding the consideration of director candidates recommended by security holders. See Item
7(d)(2(ii)(F) of Schedule 14A. Also, describe the procedures to be followed by security
holders in submitting director nominations, in accordance with Item 7(d)(2)(ii)(G) of Schedule
14A. Please also provide the disclosure required pursuant to Item 7(d)(2)(ii)(I) and (J) of
Schedule 14A as your current disclosure indicating that “[y]our directors will consider any
nomination and will consider such nomination in accordance with his or her fiduciary
responsibility...” is not descriptive enough and appears to be boilerplate disclosure.

    RESPONSE. In the future, the Company will provide all of the information required
pursuant to Item 7(d) of Schedule 14A. The Company’s proxy statement on Schedule 14A for
its 2005 annual meeting of stockholders will (1) note that the Company has now created a
standing Audit Committee, Compensation Committee, and Corporate Governance and Nominating
Committee, (2) provide the required disclosures and information regarding each of the
committees, and (3) attach copies of their charters as exhibits.

Mara L. Ransom, Esq.

April 20, 2005

Page 3

Closing Comment

The requested acknowledging statement from the Company is filed concurrently herewith.

If you have any questions or further comments, please feel free to call me directly at (310)
586-7786.

Sincerely,

/s/ JOHN C. KIRKLAND

John C. Kirkland

JCK:mb

    cc:

    Mr. Donald J. Lewis

    Andrew Jacobson, Esq.