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SEC Company Response from Sonoma Pharmaceuticals, Inc. (SNOA) (CIK 0001367083) (SNOA) — Aug 7, 2009

Sonoma Pharmaceuticals, Inc. (SNOA) (CIK 0001367083)
Date: Aug. 7, 2009 · CIK: 0001367083 · Accession: 0000950123-09-032271

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File numbers found in text: 333-157776

Referenced dates: July 31, 2009

Date
August 7, 2009
Author
/s/ Amy M. Trombly
Form
CORRESP
Company
Sonoma Pharmaceuticals, Inc. (SNOA) (CIK 0001367083)

Letter

United States Securities and Exchange Commission Division of Corporation Finance Oculus Innovative Sciences, Inc. Post-Effective Amendment on Form S-1 File No. 333-157776

Re:

Dear Mr. Kruczek:

I am securities counsel for Oculus Innovative Sciences, Inc. (the “Company”). I enclose for filing under the Securities Act of 1933, as amended, Amendment No. 2 to the Post-Effective Amendment to Form S-1, File No. 333-157776, together with certain exhibits thereto (the “Amendment”).

The Amendment contains revisions that have been made in response to the comment received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) in their letter dated July 31, 2009.

Set forth below is the Company’s response to the Staff’s comment. The numbering of the response corresponds to the numbering of the comment in the letter from the Staff.

Comment 1.

You may not deregister a transaction that has occurred. In this regard, we note your statement that this amendment seeks to deregister shares sold or transferred by the selling stockholders. Please withdraw this amendment and revise accordingly.

Response 1.

The Company has complied with the Staff’s comment.

If you have further questions or comments, please feel free to contact us. We are happy to cooperate in any way we can.

Regards,
/s/ Amy M. Trombly

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CORRESP
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corresp

August 7, 2009

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attn: Geoffrey Kruczek

    Re:

    Oculus Innovative Sciences, Inc.

Post-Effective Amendment on Form S-1

File No. 333-157776

Dear Mr. Kruczek:

I am securities counsel for Oculus Innovative Sciences, Inc. (the “Company”). I enclose for filing
under the Securities Act of 1933, as amended, Amendment No. 2 to the Post-Effective Amendment to
Form S-1, File No. 333-157776, together with certain exhibits thereto (the “Amendment”).

The Amendment contains revisions that have been made in response to the comment received from the
staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) in their
letter dated July 31, 2009.

Set forth below is the Company’s response to the Staff’s comment. The numbering of the response
corresponds to the numbering of the comment in the letter from the Staff.

    Comment 1.

    You may not deregister a transaction that has occurred. In
this regard, we note your statement that this amendment seeks
to deregister shares sold or transferred by the selling
stockholders. Please withdraw this amendment and revise
accordingly.

    Response 1.

    The Company has complied with the Staff’s comment.

If you have further questions or comments, please feel free to contact us. We are happy to
cooperate in any way we can.

    Regards,

    /s/  Amy M. Trombly

    Amy M. Trombly