SecProbe.io

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Mail Stop 03561						July 20, 2005

Anne Invernale, President
Regenesis Centers, Inc.
250 North 3rd Avenue
Delray Beach, FL  33494

Re:  	Regenesis Centers, Inc.
        	Registration Statement on Form 10-SB
        	File No.  0-51441
        	Filed July 18, 2005

Dear Ms. Invernale:

	    This is to advise you that we have reviewed only those
portions of the above registration statement that relates to the
disclosure type indicated in this letter and we have the following
comments.

Part I

Item 5.  Directors and Executive Officers, Promoters and Control
Persons
1. Disclose under appropriate caption, any prior blank check
experiences      involving officers and directors of the company.
Describe in column format the name of each company.  Include the
date
of registration and file number with the Commission and the
current
status of the company`s filings.  Also, state whether any
acquisitions, business combinations, or mergers are pending, have
occurred and the current operating status of each.

No further review of your filing will be made at this time.  You
are
requested to file an amendment on Form 10SB12G/A to include the
necessary information within fifteen business days, or inform the
staff prior to that time when the amendment will be made.

Other

      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
for
an informed decision.  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 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 be advised that your registration statement will
automatically become effective 60 days after filing.  Upon
effectiveness, you will become subject to the reporting
requirements of the Securities Exchange Act of 1934, even if we
have
not cleared your comments.  Note that the NASD Bulletin Board will
not accept your listing until we have cleared all comments.  In
the
event that it appears that you will not be able to respond by the
60th day, you may wish to consider withdrawing your registration
statement and

refiling when you have prepared a response to our comments.  In
addition, should the filing become effective in its present form
the
Division would be required to consider what recommendation, if
any,
it should make to the Commission.

	Please contact the undersigned at (202) 551-3790 or Goldie B.
Walker, Financial Analyst, at (202) 551-3234 with any other
questions.

					Sincerely,

					Michael E. Karney
   					Branch Chief (Legal)
					Office of Emerging Growth Companies
					Division of Corporation Finance

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Anne Invernale, President
Regenesis Centers, Inc.
July 18, 2005
Page 3

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