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SEC Company Response from Sonoma Pharmaceuticals, Inc. (SNOA) (CIK 0001367083) (SNOA) — Sep 2, 2009

Sonoma Pharmaceuticals, Inc. (SNOA) (CIK 0001367083)
Date: Sept. 2, 2009 · CIK: 0001367083 · Accession: 0000950123-09-040339

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File numbers found in text: 333-157776

Referenced dates: August 13, 2009

Date
September 2, 2009
Author
Jim Schutz
Form
CORRESP
Company
Sonoma Pharmaceuticals, Inc. (SNOA) (CIK 0001367083)

Letter

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

Dear Mr. Kruczek:

I am the Vice President and General Counsel of Oculus Innovative Sciences, Inc. (the “Company”). In response to comments received from the staff of the Securities and Exchange Commission (the “Staff”) in their letter dated August 13, 2009, the Company acknowledges that:

•

should the Commission or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
OCULUS INNOVATIVE SCIENCES, INC.

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CORRESP
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CORRESP

[Company letterhead]

September 2, 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

    Attn:

    Geoffrey Kruczek

    Re:

    Oculus Innovative Sciences, Inc.

    Post-effective amendment on Form S-1

    File No. 333-157776

Dear Mr. Kruczek:

I am the Vice President and General Counsel of Oculus Innovative Sciences, Inc. (the “Company”).
In response to comments received from the staff of the Securities and Exchange Commission (the
“Staff”) in their letter dated August 13, 2009, the Company acknowledges that:

    •

    should the Commission or the Staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking
any action with respect to the filing;

    •

    the action of the Commission or the Staff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve the Company from
its full responsibility for the adequacy and accuracy of the disclosure in the
filing; and

    •

    the Company may not assert Staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

    Very truly yours,

    OCULUS INNOVATIVE SCIENCES, INC.

    By:

    /s/ Jim Schutz

Jim Schutz

    Vice President and General Counsel

    cc: Amy Trombly, Esq.