SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404

       DIVISION OF
CORPORATION FINANCE
      March 6, 2009
 Mail Stop 7010

Via U.S. mail and facsimile

Mr. James C. Katzaroff, President Advanced Medical Isotope Corporation 8131 W. Grandridge Blvd., Suite 101 Kennewick, WA   99336  Re: Advanced Medical Isotope Corporation
Amendment No. 1 to Registration Statement on Form 10-12G/A
Filed on February 17, 2009
File No. 0-53497
 Dear Mr. Katzaroff:   We have reviewed your filing and have  the following additional comments.
 General

1. As we indicated in comment 1 in our letter dated December 9, 2008, since you did not withdraw the registration statement, it became effective by operation of law
60 days after you initially f iled it (January 12, 2009).   Please note that in addition
to responding to our comments on the Fo rm 10 you are subject to the reporting
requirements of the Exchange Act. Therefore, please file your December 31, 2008 Form 10-K by March 31, 2009.

2. As previously requested, please provide, in  writing, a statement directly from the
company acknowledging that:

• the company is responsible for the adequacy and accuracy of the disclosure in
their filings;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking a ny action with respect to the filing;
and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
March 6, 2009 Page 2   Item 1.  Description of Business, page 4

3. The third paragraph states that the regist rant acquired the assets of Neu-Hope
Technologies and $310,000 from UTEK Cor poration.  Please reconcile this
statement with the disclosu re in your response to comme nt 2 in our letter dated
December 9, 2008 that the company ac quired the assets of Neu-Hope
Technologies and $335,000 from UTEK Corpor ation. Also clarify the relationship
between NHTI and UTEK, and whether th e 100,000 preferred stock issued to
UTEK and Aware Capital Co rporation was the purchase price for the acquisition
of the cash and the assets of NHTI.
4. Please describe Aware Capital Corporati on in greater detail and disclose any
relationship between it and UTEK Corporation.  Also, explain why Aware Capital
received 5,000 of UTEK’s 100,000 Series A Preferred Stock.
5. We note your response to comment 6 in  our letter dated December 9, 2008.
Please include your response in this section of the filing.
 Item 1A.  Risk Factors

We have increasing cash requirements, page 10
6. Note that the registrant anticipates a $10 million requirement over the next twelve months to fund its planned business op erations.  The company currently has
approximately $54,508 in cash on hand as noted in Note 1 of the Notes to Consolidated Financial Statements.  Disc uss the potential risk to the company’s
plan of operations as discussed in the liquidity section of MD&A on page 17.

Item 2 – Financial Information, page 16

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

7. We remind you to discuss your results of operations with respect to the most
recent fiscal year-to-date period for wh ich an income statement is provided
compared to the corresponding year-to-date period of the preceding fiscal year.
You should also discuss the results of operations for the most recent fiscal quarter compared to the corresponding fiscal quarter  in the preceding fiscal year.  Please
revise as necessary.  Refer to Item 303(b)(2) of Regulation S-K.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
March 6, 2009 Page 3   Liquidity and Capital Resources, page 17

8. You disclose on page 17 that you “e xperienced negative cash flow from
operations of $737,786, and [you] expe nded $1,515,232 for investing activities
while adding $2,221,507 from financing activit ies” during the nine months ended
September 30, 2008.  It appears that these amounts actually relate to the six months ended June 30, 2008.  As such, pleas e update to reflect the amounts for
the nine months ended September 30, 2008.
 Item 4. Security Ownership of Certain Be neficial Owners and Management, page 22

9. We note your response to comment 27 in our letter dated December 9, 2008.
Please reconcile the shares held by UTEK in the table of 8,609,041 to the 8,309,399 amount in footnote (2) or explai n the difference in the footnote.
 Item 6.  Executive Compensation

 Narrative to Summary Comp ensation Table, page 25

10. In addition to the terms of the employm ent agreements which you have disclosed,
the narrative discussion should include th e material terms of the bonuses awarded
to the named executive officers during the last completed fiscal year, including a
general description of the fo rmula or criteria to be applied in determining the
amounts payable and vesting schedule.
11. The narrative discussion should also disclo se the material terms of each option
award as required by Item 402(o)(4) of Regulation S-K.
12. As previously requested, for each trans action please identify the person(s) to
whom the options were granted.  In the first paragraph, desc ribe the type of
consulting services performed by th e consultant during April, 2007.
 Item 7.  Certain Relationsips a nd Related Transactions, page 31

 Indebtedness from related parties, page 31

13. Disclose the purpose(s) of the loans from the employee.  Please confirm
supplementally that the employee was not an  affiliate of any officer or principal
shareholder of the company.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
March 6, 2009 Page 4   Item 15 – Financial Statements and Exhibits, page 36

Financial Statements for the Year Ended December 31, 2007

Note 2 – Summary of Significant Accounting Policies, page F-9

General

14. We reissue prior comment 49.  Your disc losures on pages F-10 and F-11 indicate
that you did not consider the expected future operating cash flows in assessing
your assets for impairment because they we re purchased recently.  Please further
advise how you made this determina tion in accordance with SFAS 144, or as
previously requested, please enhance your  disclosure to identify each of the
significant assumptions used in your analys is and explain the ba sis for each such
assumption.  Please also expand your disclo sure to provide additional insight on
how you perform your impairment anal ysis under SFAS 144 to include the
following:

• Please clarify how you determine when to test for impairment.  Please expand
your discussion to state the types of ev ents and circumstances that you believe
indicate impairment.  Please address how frequently you evaluate for these
types of events and circumstances; and

• Please discuss the specific valuation met hods used to determine fair value.
You should discuss how sensitive the fair  value estimates are to each of these
significant estimates and assumptions used as well as whether certain
estimates and assumptions are mo re subjective than others.
 Note 10 – Capital Lease Obligations, page F-20

15. We have reviewed your response to prior comment 47.  Given that you were not
in compliance with the minimum debt se rvice coverage ratio of 1:1 as of
December 31, 2007, please revise your disclo sure to clearly disclose the actual
ratio achieved as of each reporting date.  Please also consider showing the specific computations used to arrive at the actual ratios/amounts with corresponding
reconciliations to US GAAP amounts, if n ecessary.  See Sections I.D and IV.C of
the SEC Interpretive Release No. 33-8350 and Question 10 of our FAQ Regarding the Use of Non-GAAP Financ ial Measures dated June 13, 2003.  In
addition, please confirm that the capital lease is your  only class of debt that
contains covenants.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
March 6, 2009 Page 5
16. We have reviewed your response to prior co mment 57.  It is still unclear what the
initial amounts were for which you recorded  an asset and obli gation in September
2007 related to each of the capital leases  pursuant to paragraph 10 of SFAS 13 as
well as how you determined these amounts.   Please revise your disclosure
accordingly.

Preferred Stock, page F-23

17. We have reviewed your responses to pr ior comments 60 and 61.  We continue to
have difficulty understanding your accoun ting of the preferred stock.  Please
provide us with a comprehensive explan ation of your accounting which addresses
the following:

• Please tell us what consideration you  gave to SFAS 133 and EITF 00-19 in
accounting for the conversion feature, with  specific reference to paragraphs 20
through 24 of EITF 00-19.  Please clearly state how you accounted for and
determined the appropriate accounting for the conversion feature.  If you
recorded a liability amount related to this feature, please tell us how you
determined the amount to record;

• Based on your response, it is unclear wh at the Preferred Stock Redeemable
line item represents given that it does not  appear that the preferred stock is
redeemable for cash or other assets.  Pl ease confirm that the preferred stock is
not redeemable for cash or other assets .   Please help us understand how your
presentation complies with SFAS 150 or EITF D-98; and

• It is not clear how you determined the amount to be recorded as preferred
stock in your stockholders’ equity section.  Please advise and also tell us what
accounting literature you referen ced to support your conclusion.
   Please respond to these comments 10 business days, or tell us when you will provide us with a response.  Please provide us with a response letter that keys your
responses to our comments and provides a ny requested information.  Detailed letters
greatly facilitate our review .  Please file your response on EDGAR as a correspondence
file.  Please understand that we may have additional comments after reviewing your
responses to our comments.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation March 6, 2009 Page 6    You may contact Jeffrey Gordon, Accountant at (202) 551-3866 or Nudrat Salik,
Reviewing Accountant at (202) 551-3692 if  you have questions regarding comments on
the financial statements and related matters.  Please contact Dorine H. Miller, Financial
Analyst at (202) 551-3711 or Brigitte P. Lippmann, Senior Staff Attorney at (202) 551-3713 with any other questions.         S i n c e r e l y ,            Pamela A. Long        A s s i s t a n t  D i r e c t o r   cc: Andrea Cataneo, Esq.  Sichenzia Ross Friedman Ference LLP  61 Broadway, 32nd Floor  New York, NY 10006