SecProbe.io

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                          SYNOVA HEALTHCARE GROUP, INC.
                       1400 N. PROVIDENCE ROAD, SUITE 6010
                                 MEDIA, PA 19063

                                 August 11, 2005

VIA EDGAR AND FACSIMILE
-----------------------
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549

         RE:      SYNOVA HEALTHCARE GROUP, INC. (THE "COMPANY")
                  REGISTRATION STATEMENT ON FORM SB-2, AS AMENDED
                  FILE NO. 333-123498 ("REGISTRATION STATEMENT")
                  --------------------------------------------------

Dear Sir/Madam:

         The Company hereby requests that the above-referenced Registration
Statement be declared effective by the Commission on Friday, August 12, 2005 at
4:00 p.m. Eastern time or as soon as practical thereafter.

         The Company acknowledges that the disclosure in the Company's filing is
the responsibility of the Company. The Company further acknowledges that the
action of the Commission or the staff acting pursuant to delegated authority in
declaring the Registration Statement effective, or accelerating the effective
date thereof, does not relieve the Company from its full responsibility for the
adequacy and accuracy of the disclosures in the Registration Statement and it
does not foreclose the Commission from taking any action with respect to the
Registration Statement.

         The Company also represents to the Commission that should the
Commission or the staff declare the Company's Registration Statement effective
or accelerate the effective date thereof, the Company will not assert this
action as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

         The Company is aware of its responsibilities under the Securities Act
of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as
they relate to the above-referenced proposed public offering of securities.

                                                  Sincerely,
                                                  SYNOVA HEALTHCARE GROUP, INC.

                                                  By: /s/ David J. Harrison
                                                     ---------------------------
                                                          David J. Harrison
                                                          President

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                                 BLANK ROME LLP

                                 August 11, 2005

Mr. Jay Ingram
United States Securities and Exchange Commission
Mail Stop 3561
100 F. Street, N.E.
Washington, D.C. 20549

         Re:      SYNOVA HEALTHCARE GROUP, INC.
                  REGISTRATION STATEMENT ON FORM SB-2
                  COMMISSION FILE NO. 333-123498
                  -----------------------------------

Dear Mr. Ingram:

         In response to your request, I am writing this letter on behalf of our
client, Synova Healthcare Group, Inc. (the "Company"). This letter confirms that
the Company has informed us that shortly after the above-referenced registration
statement (the "Registration Statement") is declared effective, the Company
intends to mail copies of the final prospectus to the selling stockholders,
along with a reminder that the selling stockholders are required to comply with
all applicable state securities laws prior to selling their securities under the
Registration Statement. In addition, the Company has informed us that it intends
to offer the selling stockholders, upon request, reasonable assistance in
ascertaining what is required under any state securities laws applicable to a
specific transfer (or transfers).

         If you have any questions, or need further explanation, please feel
free to contact me.

                                                  Sincerely

                                                  /s/ Alan H. Lieblich
                                                  ------------------------------
                                                      Alan H. Lieblich

                                                  For Blank Rome LLP

cc:      Stephen E. King
         Alan L. Zeiger, Esquire

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