SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE
        December 9, 2008
 Mail Stop 7010     Mr. James C. Katzaroff, President Advanced Medical Isotope Corporation 8131 W. Grandridge Blvd., Suite B Kennewick, WA   99336  Re: Advanced Medical Isotope Corporation
Registration Statement on Form 10 Filed on November 12, 2008 File No. 0-53497

Dear Mr. Katzaroff:
  We have reviewed your filing and have the following comments.  Where indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure.  Af ter reviewing this information, we may or
may not raise additional comments.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 General

1. Please note that the registration statemen t becomes effective by lapse of time 60
days after you filed it, and accordingly will trigger the registrant’s reporting
obligations pursuant to Section 12(g) of th e Exchange Act.  However, we will not
clear the filing until all our comments are addressed. If our comments are not addressed within this 60 day time period, you should withdraw the Form 10 prior
to effectiveness and refile a new Form 10 that includes change s responsive to our
comments.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
December 9, 2008 Page 2  Item 1.  Description of Business, page 4

 Organizational History, page 4

2. Please disclose in this section that your  auditors have issued a going concern
opinion.

3. In the third paragraph, identify the natural person(s) who controls UTEK Corporation.  Disclose any relations hip between the registrant and UTEK
Corporation prior to the acquis ition of Neu-Hope Technologies.

4. Disclose the number of shar es and percentage of total outstanding shares that
would be issuable if UTEK Corporation c onverts the Series A pr eferred stock into
common stock and who will exercise vo ting and investment power over those
shares of common stock.  Similar disclosure  should be provided  in footnote 2 to
the table under “Item 4.  Security Owner ship of Certain Beneficial Owners and
Management” on page 21.

5. Please describe the assets acquired in gr eater detail and disclose the manner in
which the purchase price of the acquired assets was determined in the third and fourth paragraphs.

6. We note your disclosure that James Katzaroff currently serves as Manakoa Services Corporation’s CEO.  We also note the media reports that in January 2007
Manakoa acquired a UTEK Corporation subsidiary, Infinite Identification Technologies Inc. Please explain these re lationships and describe Manakoa’s and
UTEK past affiliations and transactions w ith the company.  Also describe in this
section Mr. Katzaroff’s affiliation with Manakoa and disclose whether it is a shell or blank check company.  Further disc lose whether Manakoa is still a public
company and, if so, whether it is current in filing its periodic reports.
 Products, page 5

7. Throughout this section you us e technical jargon that is  difficult to understand.
Please revise to discuss your business mo re clearly.  For example, we note under
“Manufacturing” on page 6 that you refer to FDG as the radio-labeled glucose
analog and you refer to PET as Positron Emission Tomography. Please move these clarifications to the section wher e you first make reference to the terms
FDG and PET.  Also briefly note the intended application of the F-18 FDG
referred to on page 5.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
December 9, 2008 Page 3  Radio Pharmaceuticals: Indium-111, page 5

8. Please delete the word “soon” and disclose a more specific date on which you intend to offer Indium Chloride st erile solution and Indium Oxine.
 Manufacturing, page 6

9. Please disclose the basis for your asserti on that no other accelerator in North
America has sufficient flexibility to pr oduce the full spectrum of PET imaging
radioisotopes for diagnostic and therapeu tic applications. If you funded or were
otherwise affiliated with a ny of the studies or report s you cite, please disclose
this. Otherwise, please confirm that these sources are widely available to the public. If you do not have appropriate i ndependent support for this statement,
please revise the language to make clear that this is your belief based on your
experience in the industry, if true.
 License Agreement, page 7

10. Please file as exhibits the Non-Exclusive License Agreement between the registrant and Regents of the Univer sity of California and any material
collaborative or research agreements you have entered into, as discussed under
“Manufacturing” or advise us why the agr eements are not required to be filed.
Please see Item 601(b)(10) of Regulation S-K.

11. We note that if your commercialization pl an is deemed unacceptable, the license
agreement will terminate and “may be converted to a non-exclusive license.”  Please clarify the statement since you ha ve already indicated that it is a non-
exclusive license.

12. We note your disclosure under Item 2 regarding your operating expenses
attributed to amortization of licenses.  Please disclose the material terms of the
license and the estimated economic  useful life of this asset.

Raw Materials, page 7

13. Please discuss the availability of the stab le isotopes obtained from suppliers in
Russia.  Reconcile this disclosure with  the discussion under “Risk Factors – We
rely heavily on a limited number  of suppliers” on page 14.

Customers, page 7

14. We note in the Risk Factor section on page 11, that “unanticipated contract
terminations by current customers can negatively impact operations . . .”  Please

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
December 9, 2008 Page 4
disclose whether you are dependent on one or a few major customers and describe
any contracts with these customers.

15. Please describe the company’s relationship with United Pharmacy Partners Inc in
more detail.
 Research and Development, page 8

16. Please disclose the duration of the pate nt licenses and inte llectual property you
refer to in this section.  See Item  101(h)(4)(vii) of Regulation S-K.
 Government Regulation, page 9

17. We note in the Risk Factor section on page 13, that you incur, and expect to continue to incur capital a nd operating costs to comply with environmental laws
and regulations. Please disclose the co sts and effects of compliance with
environmental laws. See Item 101( h)(4)(xi) of Regulation S-K.
 Item 1A.  Risk Factors

 We have increasing cash requirements, page 10

18. Disclose the cumulative amount of operating losses incurred from inception to date.
 Item 2.  Financial Information, page 16

 Management’s Discussion and Analysis of Fi nancial Condition and Results of Operation,
page 16
 General

19. Please expand MD&A to provide a discussion of the effect of recent economic events on your operations, financial position and liquidity.  This disclosure should
provide detailed information on your cust omers, recent order activity, expected
trends, management’s response for managing these events, poten tial future actions
by management and other detailed information.
 Results of Operations, page 16

20. Please discuss in greater detail the bu siness reasons for the changes between
periods in revenue and cost of goods so ld.  In doing so, please disclose the
amount of each significant change in line items between  periods and the business
reasons for it.  In circumstances where th ere is more than one business reason for

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
December 9, 2008 Page 5
the change, attempt to quantify the increm ental impact of each individual business
reason discussed on the overall change in  the line item.  See Item 303(a)(3) of
Regulation S-K.

21. Please revise your disclosure to also di scuss the business reasons for the changes
in operating expenses and net loss for the subsequent interim period.  Your
current disclosure only discusses the cha nges in operating expenses and net loss
for the two years ended December 31, 2007.

22. You disclose on page 17 that your net loss for the six months ended June 30, 2008
was $2,234,955.  Based on your statement of oper ations, it appears that your net
loss was actually $2,696,782.  Please revise or advise.
 Liquidity and Capital Resources, page 17

23. Please provide a comprehensive discussion of your liquidity given your recurring
losses and use of cash in operations and ensure you also disclose any known and anticipated trends, demands, commitments, events or uncertainties that are reasonably likely to materially increase or  decrease liquidity.  In addition, please
expand your liquidity discussion to addre ss the expected imp act to current and
future cash flows and how you expect recent economic events, including the
credit shortage, may affect ot her sources of liquidity.

Contractual Obligations, page 17

24. Please revise your table so that the sum of your contractual obligations for each
period and in total appears at the bottom of the table.
 Recent Accounting Pronouncements, page 18

25. We note that you are curren tly evaluating the impact of the adoption of SFAS
155, 156, 157, 159 and FIN 48.  Since these pronouncements are already effective for you, please revise to disclose your c onclusion of the impact of adoption of
these pronouncements.
 Item 3. Description of Property, page 20

26. Please explain in the first paragraph why the lease agreement entered into on July 17, 2008 was made effective approximately  one year earlier on August 1, 2007.
Indicate that rent for the year beginning August 1, 2009 will be
 $4,092.  Please
verify the accuracy of the calculation s of the monthly rental amounts.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
December 9, 2008 Page 6  Item 4.  Security Ownership of Certain Beneficial Owners and Management, page 21

27. Please update the November 12, 2008 date to  the most recent practicable date and
reconcile the number of shares  issuable to UTEK with th e calculation disclosed in
footnote 2.
 Item 5. Directors and Executive Officers, page 21

28. In each director’s and executive officer’s  biography, please disclose the dates of
his term of office with the registrant.  Also, briefly describe their principal occupations and employment during the last  five years, indicating the period of
time such occupation and employment we re carried on.  For each director,
indicate any other director ships held by such person. See Item 401 of Regulation
S-K.
 Item 6.  Executive Compensation, page 23

29. Please include a narrative description of the summary compensation table,
including disclosure regarding the officer s’ employment agreements.  See Item
402(o) of Regulation S-K.

30. Please identify the persons who performed the consulting services and describe
the type of consulti ng services performed.
 Director Compensation, page 26

31. Please provide the director compensation table required by Item 402(r) of Regulation S-K.
 Item 7.  Certain Relationships a nd Related Transactions, page 27

32. Identify the parties to each relate d party transaction in this section.

33. Please provide the disclosure required by Item 404(c) of Regulation S-K.  Since it
appears that the company was a shell until 2006, also provide the disclosure
required by Item 404(c)(2) of Regulation S-K.

34. Please provide a list of a ll parents of the company s howing the basis of control
and as to each parent, the percentage of voting securities owned or other basis of
control by its immediate parent, if any. See Item 404(d)(3) of Regulation S-K.

35. Please describe in greater detail the busi ness dealings with Mirari, including the
following:

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
December 9, 2008 Page 7
• Disclose the business reasons for advanc ing funds to Mirari in the amount of
$33,000 and why this was written off as bad debt.
• Explain why the company purchased the not e receivable due Mi rari in the amount
of $28,500 and why this investment was written off in 2006.
• Describe the assets the comp any proposes to acquire from  Mirari and disclose the
proposed acquisition costs of Mirari in 2008.
• As to the assets acquired or to be acqu ired by the registrant  from Mirari, provide
the disclosure required by Item 404(c)(1)(ii) of Regulation S-K.
 Item 10.  Recent Sales of Unregistered Securities, page 29

36. For each sale of unregistered securities  transaction, expand the description to
disclose the aggregate considered receiv ed by the company and the per share price
at which the securities were issued. As to any securities sold otherwise than for
cash, state the nature of the transaction and the nature and aggregate amount of
consideration received by the registrant .  See Item 701(c) of Regulation S-K.

37. For each transaction, please give the name s of the principal underwriters, if any.
For the transactions consummated in 2008, name the persons or  identify the class
of persons to whom the securities were sold. See Item 701(b) of Regulation S-K.

38. Indicate the section of the Securities Act or the rule of the Commission under
which exemption from registration was claimed and state briefly the facts relied upon to make the exemption available. See Item 701(d) of Regulation S-K.

39. Please include the securitie s transactions lis ted on pages F-28, and F-40 through
F-42.
 Item 11.  Description of Registrant’s Securities to  be Registered, page 31

40. Please update the October 3, 2008 date in the first paragraph and disclose the
amount of securities issuable upon exerci se of outstanding options, warrants and
rights.
 Item 14. Changes in and Disagreements with Accountants on Accounting and Financial
Disclosure, page 32

41. Please revise your disclosure to state the specific date of dismissal of your former accountant, as required by Item 304(a)(1)( i) of Regulation S-K.  In addition,
please disclose the date that you engaged HJ and Associates, LLC.  See Item 304(a)(2) of Regulation S-K.

42. In addition, Item 304(a)(1)(ii) of Regulat ion S-K requires a statement whether the
accountant's report on the financ ial statements for either of the past two years

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
December 9, 2008 Page 8
contained an adverse opinion or a disc laimer of opinion or was qualified or
modified as to uncertainty, audit scope or accounting principles; and a description
of the nature of each such adverse opin ion, disclaimer of opinion, modification or
qualification.  This would include disclosu re of uncertainty regarding the ability
to continue as a going concern in th e accountant’s report.  Please revise
accordingly.
 43. Please include as an exhibit the letter  from your former accountant indicating
whether or not they agree with your disclosures.  See Item 304(a)(3) of
Regulation S-K.
 Item 15.  Financial Statements and Exhibits, page 33

 Financial Statements for the Year Ended December 31, 2007

 General

44. Please disclose in your financial statements the amount of research and development costs you have incurred for the fiscal years ended December 31, 2007 and 2006.  See paragraph 13 of SFAS 2.

Balance Sheets, page F-3

45. Based on your statements of changes in shar eholders’