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SEC Company Response from Sonoma Pharmaceuticals, Inc. (SNOA) (CIK 0001367083) (SNOA) — Jul 24, 2009

Sonoma Pharmaceuticals, Inc. (SNOA) (CIK 0001367083)
Date: July 24, 2009 · CIK: 0001367083 · Accession: 0000950123-09-025076

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File numbers found in text: 333-158539

Date
July 24, 2009
Author
Albert Poliak
Form
CORRESP
Company
Sonoma Pharmaceuticals, Inc. (SNOA) (CIK 0001367083)

Letter

United States Securities and Exchange Commission Division of Corporation Finance Attention: Geoffrey Kruczek Re: Oculus Innovative Sciences, Inc. File No. 333-158539

Dear Mr. Kruczek:

Pursuant to Rule 461 of the Rules and Regulations promulgated under the Securities Act of 1933, as amended, the undersigned, as the placement agent of units as described in the above-captioned Registration Statement on Form S-1 (the “Registration Statement”), hereby join in the request of Oculus Innovative Sciences, Inc. that the effectiveness of the Registration Statement be accelerated to July 24, 2009 at 4:30 pm EST or as soon as practicable thereafter.

In connection with this acceleration request and pursuant to Rule 460 of the Securities Act, the following information is provided with respect to the distribution to date, of the preliminary prospectus dated July 21, 2009:

Number of

To Whom Distributed

Copies

Underwriters

—

Institutional Investors

Individuals

Other Broker-Dealers

1,028

Total

1,636

With respect to Rule 15c2-8 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), the undersigned has distributed or will distribute copies of the preliminary prospectus at least 48 hours prior to the date confirmations of sale are expected to be mailed. In addition, each underwriter and each selected dealer, if any, will represent to the undersigned that it has and will comply with Rule 15c2-8 under the Exchange Act.

Very truly yours,
DAWSON JAMES SECURITIES, INC.

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CORRESP
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filename1.htm

CORRESPONDENCE

[Company Letterhead]

July 24, 2009

VIA FACSIMILE TO (703) 813-6985 AND EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E., Mail Stop 3030

Washington, DC 20549

Attention: Geoffrey Kruczek

    Re:

    Oculus Innovative Sciences, Inc.

    File No. 333-158539

Dear Mr. Kruczek:

Pursuant to Rule 461 of the Rules and Regulations promulgated under the Securities Act of 1933, as
amended, the undersigned, as the placement agent of units as described in the
above-captioned Registration Statement on Form S-1 (the “Registration Statement”), hereby join in
the request of Oculus Innovative Sciences, Inc. that the effectiveness of the Registration
Statement be accelerated to July 24, 2009 at 4:30 pm EST or as soon as practicable thereafter.

In connection with this acceleration request and pursuant to Rule 460 of the Securities Act, the
following information is provided with respect to the distribution to date, of the preliminary
prospectus dated July 21, 2009:

    Number of

    To Whom Distributed

    Copies

    Underwriters

    —

    Institutional Investors

    46

    Individuals

    562

    Other Broker-Dealers

    1,028

    Total

    1,636

With respect to Rule 15c2-8 under the Securities Exchange Act of 1934, as amended (the “Exchange
Act”), the undersigned has distributed or will distribute copies of the preliminary prospectus at
least 48 hours prior to the date confirmations of sale are expected to be mailed. In addition,
each underwriter and each selected dealer, if any, will represent to the undersigned that it has
and will comply with Rule 15c2-8 under the Exchange Act.

    Very truly yours,

DAWSON JAMES SECURITIES, INC.

    /s/ Albert Poliak

    By:  Albert Poliak, President