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    invo-coresp02172009.htm

    INVO
Bioscience, Inc.

    100
Cummings Center,

    Suite
421E

    Beverly,
Massachusetts 01915

                                                 February 17,
2009

    VIA EDGAR

    U.S.
Securities and Exchange Commission

    Mail Stop
3561

    Washington,
D.C. 20549-0405

    Attention:  Ta
Tanisha Meadows

    Re:  Emy’s
Salsa Aji Distribution Company, Inc.

            Item
4.01 Form 8-K, File No: 333-147330

    Dear Ms.
Meadows:

    We have
set forth below our responses to the Staff’s comments raised in your letter
dated December 12, 2008, regarding Item 4.01 on Form 8-K (the “Registration
Statement”) for INVO Bioscience, Inc., formerly Emy’s Salsa Aji Distribution
Company, Inc. (the “Company”) that we filed on December 12, 2008.  For
ease of your review, the Company’s responses are set forth below the text of
each comment raised in your letter.  In addition, we have filed an
amendment to the Registration Statement on Form 8-K/A to address these comments
and to address typographical and other changes.

    Item 4.01 Form 8-K Filed
December 12, 2008

              1.

              We note that the date of the
      earliest event reported on the cover page is December 5, 2008 and you
      disclose under Item 4.01 that Berman was dismissed and Webb & Co. was
      engaged on December 4, 2008.  We also note that the letter filed
      as Exhibit 4.1 states that Berman was dismissed on December 5,
      2008.  Please revise or
advise.

    We have
revised the disclosure in Item 4.01 to clarify that indeed Berman was dismissed
on December 5, 2008 and that Webb & Co. was engaged by the Company as of
that same date.

              2.

              Please state whether the
      decision to change accountants was recommended or approved by the board of
      directors or any audit or similar committee of the board of
      directors.  Refer to paragraph (a)(1)(iii) of Item 304 of
      Regulation S-K.

    We have
revised the disclosure in Item 4.01 to clarify that our Board of Directors
approved the dismissal of Berman.

              3.

              Please revise your disclosures
      in the first and second paragraphs of item (1) to state the specific
      period during which there were no disagreements with Berman and no
      reportable events.  This period should include the two most
      recent years and any subsequent interim period preceding the dismissal of
      Berman on December 4, 2008.  Refer to paragraph (a)(1)(v) of
      Item 304 of Regulation S-K.

    We have
revised the disclosure in Item 4.01 to clarify that the there were no
disagreements with Berman and no reportable events during the two most recent
years and any subsequent interim period preceding the dismissal of Berman on
December 5, 2008.

              4.

              Please revise your disclosure
      in item (2) regarding the specific period during which there was no
      consultation with Webb & Co.  This period should include the
      two most recent years and any subsequent interim period preceding the date
      of the engagement of Webb & Co. on December 4, 2008.  Refer
      to paragraph (a)(2) of Item 304 of Regulation
  S-K.

    We have
revised the disclosure in Item 4.01 to clarify that there was no consultation
with Webb & Co. during the two most recent years and any subsequent interim
period preceding the engagement of Webb & Co. on December 5,
2008.

        U.S.
Securities and Exchange Commission

        February
17, 2009

        Page
2

              5.

              Please note that you are also
      required to file a letter from Berman stating whether the firm agrees with
      the statements made in any amendment to the filing and, if not, stating
      the respects in which the firm does not agree.  The updated
      letter should be filed within two business days of its receipt or 10
      business days after filing any amendment as Exhibit 16.1 as opposed to
      Exhibit 4.1.  Please acknowledge this
      obligation.  Refer to Items 304(a)(3) and 601(b)(16) of
      Regulation S-K.

    We have
received and filed an updated letter from Berman stating that the firm agrees
with the statements made in the amendment to Item 4.01 in the filing on Form
8-K/A.

    In
connection with our foregoing responses to your comments, we acknowledge hereby
that:

              ·

              The
      Company is responsible for the adequacy and accuracy of the disclosures in
      the filing;

              ·

              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 this action as a defense in any proceeding
      initiated by the Commission or any person under the federal securities
      laws of the United States.

    *    *    *    *

    If you
have questions regarding this matter or if you need additional information,
please do not hesitate to me contact me on 978-878-9505 or Debbie Klis, of
Shulman, Rogers, Gandal, Pordy & Ecker, P.A., 11921 Rockville Pike, Suite
#300, Rockville, Maryland 20852, counsel to the Company, at (301)
230-5241.  Thank you in advance for your time and
attention

    Sincerely,

    /s/ Katie
Karloff

    Katie Karloff

    Chief Executive Officer

    cc:  Scott
Museles, Esq., Shulman Rogers et al

           Elliot
Berman, CPA, Berman & Co.

           Derek
Webb, CPA, Webb & Co.

           Robert
Bowdring, CFO, INVO Bioscience

           Dr.
Claude Ranoux