SecProbe.io

November 3, 2010

William Morland, Chief Executive Officer HealthMed Services Ltd. 1250 Oakmead Parkway Sunnyvale, CA 94085

Re:  HealthMed Services Ltd.
Form 10-K for Fiscal Year Ended December 31, 2009 Filed March 31, 2010 Form 10-Q for Fiscal Quarter Ended June 30, 2010  Filed August 23, 2010 File No. 333-152439
 Dear Mr. Morland:
 We have reviewed your filings and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within te n business days by amending your filing(s), by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment(s) and the in formation you provide in response to these
comments, we may have additional comments.

Form 10-K for the Fiscal Year Ended December 31, 2009

 Cover page

 1. The cover page appears to present the aggregate market value of your common stock held by non-affiliates as of March 22, 2010, instead of as of the end of the most recently-completed second  fiscal quarter (i.e., June 30, 2009), as called for by Form 10-K.  Please
confirm that you will provide this information as of the appropriate date in future filings.
 Item 1. Business, page 4

 2. Please revise your disclosure in Business a nd Management’s Discussion and Analysis of
Financial Condition and Results of Operations  to express clearly the status of the
company’s business.  It is uncl ear from the disclosure provided  in these sections what, if
anything, the company has accomplished to date from an operational perspective.  State

Mr. William Morland
HealthMed Services Ltd.
November 3, 2010 Page 2

what you have accomplished to date and what remains to be accomplished in order for you to begin to generate revenues.  For exampl e, we note risk factor disclosure on page 9
stating that your website is ope rational but requires additional work before being able to
generate revenues.  Please discuss more sp ecifically the current functionality of your
website and the additional work you intend to do on it, and disclose the website address.
 3. You disclose that you intend to offer medical advice, information, products and services through your website and call cen ters.  As a development stage company, any discussion
of your business plans should be balanced with disclosure that your business may not materialize in the event you ar e unable to execute on your plan.  Ensure that all claims
relating to events that you exp ect to occur at a future time ar e expressed as objectives that
may not be accomplished.  With respect to stat ements that predict accomplishments in the
future, expand to provide meaningful discussions  of the events or circumstances that may
prevent the accomplishment of these objectives.  In addition, please ensure that
references to your website reflect  the status of its development.

4. Please also ensure that disclosure throughout th e filing is up-to-date.  For example, please
revise your statement on page 8 that you intend to roll out your “less co stly, more flexible
ASP system in the US market in third quart er 2009,” to reflect the company’s current
expectations and ope rational status.

5. Please specifically disclose the factual basis for and the context of your claims, beliefs and opinions set forth in your Form 10-K.  You must be able to substantiate on a
reasonable basis all such claims, beliefs a nd opinions.  Avoid making promotional claims
that lack a reasonable basis.   We note, as  examples only, the following statements that
appear to require support:

o “[W]e anticipate that we will be competi tive in all aspects of the domestic and
international market for health information services,” page 6:
o “[Our application service provider] will provide a 30% price advantage over the competition with the flexibility to custom ize outsourced services to the needs of
large insurers,” page 7;
o “[O]ur proposed accreditation by the Am erican Health care Accreditation
Commission (URAC) gives us direct access to the HMOs and others that have
sought this prized accreditation in their own fields,” page 7; and
o “We have positioned ourselves as a central  player in the ‘Connected Health
Marketplace’ that is transforming hea lth care systems globally,” page 9.
 Item 1A. Risk Factors, page 9

 6. Please provide risk factor disc losure addressing risks relate d to the going-concern opinion
issued by your auditor.

Mr. William Morland
HealthMed Services Ltd.
November 3, 2010 Page 3

“Because we have two directors…,” page 10

 7. This risk factor discusses risks associated with having an even numb er of directors, but
your disclosure regarding directors and execu tive officers beginning on page 21 indicates
that the company has only one  director.  Please advise.
 Item 5. Market for Registrant’s Common Equ ity, Related Stockholder Matters and Issuer
Purchases of Equity Securities, page 12
 8. Please tell us why you have not provided the high and low bid information for your
common stock for the quarterly periods e nded June 30, September 30, and December 31,
2009.  In this regard, we note that disclosure in this secti on, including the opening
paragraph and footnote 2 to th e table, suggests that your co mmon stock has been quoted
on the Over-the-Counter Bulletin Board sin ce November 10, 2008.  Please also clearly
indicate in your disclosure periods for which there is or was no established public trading
market for your common stock.  Refer to  Item 201(a) of Regulation S-K.
 Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations

Liquidity and Capital Resources, page 14

9. You disclose that you will require additional fi nancing in order to proceed with your plan
of operations, including approximately $17,000 ove r the next 12 months to cover planned
expenses.  State the minimum period of tim e that you anticipate being able to conduct
planned operations using curren tly-available capital resources.  Quantitative information
regarding your financial requirements is n ecessary to enable investors to assess the
company’s financial condition and the likeli hood it will be able to pursue its business
plan.  See Item 303(a)(1) of Regulation S-K.
 Item 9A. Controls and Procedures

 Management’s Report on Disclosure Controls and Procedures, page 19

 10. We note that you identified several materi al weaknesses as part of management’s
evaluation of the effectiveness of your intern al control over financ ial reporting as of
December 31, 2009, and that your management c oncluded that your internal control over
financial reporting was not effective as of the evaluation date due to these material
weaknesses.  The identified weaknesses include insufficient resources, inadequate
segregation of duties, and l ack of an audit committee.  Please explain to us how
management considered these material wea knesses in concluding th at your disclosure
controls and procedures were effective as  of December 31, 2009.  Alternatively, revise
your filing as necessary.  This comment also applies to your Form 10-Q for the quarterly period ended March 31, 2010, in which you di sclose that your management again

Mr. William Morland
HealthMed Services Ltd.
November 3, 2010 Page 4

concluded that your disclosure controls and procedures were effective.  We note in this
regard that your Form 10-Q for the quart erly period ended June 30, 2010 discloses that
your management concluded that your “discl osure controls and procedures were not
effective as of the end of the period covere d by this quarterly report due to a lack of
segregation of duties and an over-reliance on consultants invo lved in the accounting and
financial reporting process.”
Management’s Report on Internal Control over Financial Reporting, page 19

 11. We note your disclosure regarding remedial m easures the company is taking, and intends
to take or consider taking, to address the identified material weaknesses in internal control over financial reporting.  Please pr ovide an estimated timetable for on-going and
planned remediation and any associated material costs, and provide conforming
disclosure in future filings where you refer to  remediation of material weaknesses.  To
the extent your estimated timetable for remedi ation or anticipated cost changes, or there
are other material developments with respect to your plan of remediation, please provide
relevant updated information to investor s in your quarterly and annual reports.

Changes in Internal Control over Financial Reporting, page 20

12. You disclose that “[t]here have been no change s in [y]our internal controls over financial
reporting that occurred during the year ended December 31, 2009 that have materially or
are reasonably likely to materially affect, [y]our internal controls over financial reporting.”  In future annual reports on Form 10-K, please state specifically whether there
were any such changes in your internal cont rols over financial repo rting during your most
recent fourth fiscal quarter.  Refer to Item  308T(b) and Item 308(c) of Regulation S-K.
 Item 13. Certain Relationships a nd Related Transactions, and Di rector Independence, page 25

 13. You state as follows:  “Except as disclose d herein, no director, executive officer,
shareholder holding at least 5% of shares of our common stock, or any family member
thereof, had any material interest, direct or indirect, in any tr ansaction, or proposed
transaction since the year e nded December 31, 2009…..”  Please provide this disclosure
for the time period specified in Item 404(d )(1) of Regulation S-K and Instruction 2
thereto.  In addition, revise your disclosure to indicate clearly whet her there have been
any such transactions, as it is unclear fr om the phrase “Except as disclosed herein”
whether any such transactions have occurred.
 14. Further, we note your disclosure on page F- 10 regarding several capital contributions
made by the company’s founder during fis cal 2008 and 2009.  Please advise whether
your founder is a “related person” within the meaning of Instruction 1 to Item 404(a), and
if so, provide the disclosure called for by It em 404(d)(1) with resp ect to these related-
person transactions in your Item 13 disclosure.

Mr. William Morland
HealthMed Services Ltd.
November 3, 2010 Page 5

Form 10-Q for the Quarterly Period Ended June 30, 2010

 Notes to the Unaudited Financial Statements

 Note 4. Note Payable – Related Party, page 8

 15. You disclose that you entered into a $375,000 lo an agreement with a shareholder on June
30, 2010.  Please file this agreement as an exhibit pursuant to Item 601(b)(10) of
Regulation S-K, or advise.
16. In addition, please advise why you did not f ile a Form 8-K announci ng entry into this
loan agreement.  Refer to Items 1.01 and 2.03 of Form 8-K.
 Item 4. Controls and Procedures

 Management’s Report on Disclosure Controls and Procedures, page 12

 17. You disclose that your president, “acting as  [y]our principal executive officer, principal
financial officer and principle accounting officer,” concl uded that your disclosure
controls and procedures were not effective as of June 30, 2010.  This disclosure suggests
that one individual serves as both principal executive officer and principal financial officer of the company.  However, it appears from disclosure elsewhere, including from
the signatures to your Form 10-Q, that se parate individuals se rve as your principal
executive officer and principal financial offi cer.  Please confirm, if accurate, that the
conclusions presented in your Form 10-Q w ith respect to the effectiveness of your
disclosure controls and proce dures are those of both your pr incipal executive officer and
principal financial officer, as opposed to t hose of a single officer.  Provide conforming
disclosure in future filings, as appropriate.
 Exhibits 31.1 and 31.2

 18. We note that you have omitted the introductory  language in paragraph 4 and paragraph
4(b) referring to internal c ontrol over financial reporting fr om your certifications required
under Exchange Act Rules 13a-14(a) and 15d-14( a).  It appears, however, that you are no
longer permitted to omit this language in your certifications.  For gui dance, refer to our
Regulation S-K Compliance and Disc losure Interpretation No. 246.13 at
http://162.138.185.31/divisions/corpfin/guidance/ regs-kinterp.htm.  Please amend your
Form 10-Q to provide certifications that conform exactly to the language  set forth in Item
601(b)(31) of Regulation S-K.  Please not e that if you are amending your Form 10-Q
solely to provide the revised certifications, you may file  an abbreviated amendment
consisting of a cover page, an explanatory no te as to why you are filing the amendment,
the signature pages, and the revised certifications.

Mr. William Morland
HealthMed Services Ltd. November 3, 2010 Page 6

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filings to be certain that the filings incl ude the information the Secu rities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure in the filings;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filings; and

• the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of  the United States.

Please contact me at (202) 551-3483 with any questions.  If you need further assistance,
you may contact Barbara C. J acobs, Assistant Director.

Sincerely,

Katherine Wray
Attorney-Advisor
cc: Via Facsimile (602) 633-1617

 W. Scott Lawler  Becky Hermosillo  Lawler & Associates