SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE
       July 10, 2009
 Mail Stop 4631  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. 3 to Registration Statement on Form 10  Amendment No. 1 to Form 10-K for the Fiscal Year Ended December 31, 2008 Filed on June 24, 2009
  Form 10-Q for the Quarterly Period Ended March 31, 2009
Filed on May 20, 2009 File No. 0-53497
 Dear Mr. Katzaroff:   We have reviewed your filings and have the following comments.
Amendment No. 3 to Form 10

General

1. Where we ask for revisions to your disclosu re in the registration statement, please
make similar revisions in the applicable places in your Form 10-K and Form 10-Q.
 Item 1. Description of Business, page 4

2. We note that you added disclosure on  page 18 stating that in 2008 your
management concluded the patent license for the Neutron Generator was no longer of value to the company and wrot e off the net unamortized portion balance
of $643,917 early.  Further, in 2008 your management concluded the intangible
assets acquired from Isonics were no longer of value and wrote off the total net unamortized portion balance of $259,618 ear ly.  Where you discuss the patent
license and intangible assets throughout  the filing, please also update your
disclosure to discuss the related writ e-offs and the reasons why management
concluded they were of no value; for example, on pages 4, 7 and 8.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
July 10, 2009 Page 2  Item 1A.  Risk Factors, page 9

3. We note your response to comment 2 in our letter dated April 21, 2009.   Please
also describe the track record of public companies affiliated with UTEK,
including  whether any such company has not achieved profitability, implemented
its business plan or is delinquent in its periodic reporting obligations.  For
example, we note the disclosure in U TEK’s Form 10-K regarding the write down
of other investments in UTEK’s portfoli o, some of which are public companies.
 Item 2. Financial Information – Liqu idity and Capital Resources, page 18

4. We note the disclosure in  your Form 10, Form 10-K, and Form 10-Q that based
on the current cash run rate, approximately $1 million will be needed to fund your
operations for an additional year. Please expand your disclosure and reconcile this
statement with the disclosure in the going concern note in your financial
statements.  Specifically, the going con cern note reflects that you anticipate a
requirement of $3 million in funds over the next twelve months to maintain current operation activities.
 Item 5. Directors and Officers, page 23

5. We note that you added Dr. Michael Kore nko as a director.  Please update the
tables on pages 22 and 23 accordingly.
 Item 6. Executive Compensation, page 25

 Narrative to Summary Comp ensation Table, page 25

6. We note your response to comment 4 in our letter dated April 21, 2009. However,
some of the amounts in the table still do not reconcile to your narrative disclosure.
Please provide footnote disc losure explaining why Dr. Fu Min-Su’s employment
agreement provides that his annual sa lary is $90,000, but $74,615 is reflected
under his applicable salary column in the table, and explain how the bonus and
awards reflected in the table were determined. With respect to William J. Stokes, please describe the employment agreemen t you refer to in footnote (1) to the
table.
  Item 10. Recent Sales of Unregistered Securities, page 32

7. We note in your response to comment 7 in our letter dated April 21, 2009 that you
have listed numerous private offerings w ith investors.  Pleas e disclose the number
of investors in each private offering, identify the persons or the class of persons to whom the securities were sold, and briefly describe the facts relied upon to make

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
July 10, 2009 Page 3
the Section 4(2) exemption available for these offerings.  See Item 701(b) and (d)
of Regulation S-K.

8. Please provide the information required by Item 701 of Regulation S-K for the
convertible notes described in the last two paragraphs in this section, including
the names of the investors and the ex emption from registration claimed.

Financial Statements

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

9. We have reviewed your response to comm ent 8 in our letter dated April 21, 2009.
You state that the factors that led to impairment charges related to certain
unamortized license fees and intangible a ssets do not apply to  your fixed assets.
Please disclose what these factors were and how you determined that they do not
apply to your fixed assets.  Your response indicates that you did not test any fixed
assets for impairment, please confirm.  If you did test for impairment, we
encourage you to provide qualitative and quantitative descriptions of the material
assumptions used to determine fair va lue in your impairment analyses and a
sensitivity analysis of those assumptions used based upon reasonably likely changes.  For any asset groups for which the carrying value was close to the fair
value, please consider disclosing the ca rrying value of the asset groups.
 Note 10 – Capital Lease Obligations, page F-20

10. We have reviewed your response to co mment 10 in our letter dated April 21,
2009.  You indicate that you believe this obligation should be classified as non-
current since it is probable that you will cu re the default before the end of 2009.
Based on review of your March 31, 2009 balance sheet, it appear s that you have
presented this obligation as current as  of December 31, 2008 and March 31, 2009;
however, based on review of your audite d December 31, 2008 balance sheet, it
appears that you have continued to present this obligation as n on-current.  Please
advise as to the apparent inconsistenc ies between the presen tation included in
your December 31, 2008 and March 31, 2009 financial statements, as well as in your response to prior comment 10.  If you now believe that this obligation should
be presented as current as of December  31, 2008, please tell us what consideration
you gave to paragraphs 25 and 26 of SFAS 154.
 Form 10-K/A for the Fiscal Year Ended December 31, 2008

11. Please amend your Form 10-K to address the comments in this letter.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
July 10, 2009 Page 4  Item 9A(T). Controls and Procedures, page 22

12. Although your response to comment 15 in our letter dated April 21, 2009 states
you have amended the Form 10-K to pr ovide the disclosure controls and
procedures information required by Item 307 of Regulation S-K, this information
is not included in your Form 10-K.  Pleas e revise.  Note that Item 307 relates to
disclosure controls and procedures a nd the information you currently provide
relates to internal control over financial reporting, as set forth in Item 308T of
Regulation S-K.
 Signatures, page 33

13. We note your response to comment 19 in  our letter dated April 21, 2009.  The
Form 10-K should also be signed by the company’s principal accounting officer
or controller whose title should be shown on the signature page. Therefore, under
the title for Bruce Jolliff, please indicate that he is also the company’s principal
accounting officer.  See General Instruction D to Form 10-K.
 Exhibits 31.1 and 31.2 – Certifications

14. We note your response to comment 20 in our letter dated April 21, 2009;
however, the revision in the first bullet point of our co mment is not reflected in
the certifications. The ce rtifying individuals included their titles in the
introductory sentence of the certificat ions required by Item 601(b)(31) of
Regulation S-K.  Please remove their title s from the introductory  sentence of the
certifications.
 Form 10-Q for the Quarterly Period Ended March 31, 2009

15. Please amend your Form 10-Q to address the comments in this letter.
 Item 4T. Controls and Procedures, page 25

16. Please revise your disclosure throughout th is section to clarify whether you are
referring to disclosure controls or pro cedures or internal control over financial
reporting.  See Item 307 and Item 308T of Regulation S-K.

17. You disclose “this annual report does not include an attestation report by our
registered public accounting firm regard ing our internal controls over financial
reporting.”  Since this is not an annual re port, please remove this disclosure in
future Form 10-Q filings.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation July 10, 2009 Page 5  Exhibits 31.1 and 31.2 – Certifications

18. Please file an amendment to the Form 10-Q that includes the enti re periodic report
and new, corrected certifications.  Revise  your certifications to reflect the exact
form set forth in Item 601(b)(31) of Regulation S-K.  In that regard, please make the applicable revisions se t forth in comment 20 in our letter dated April 21, 2009.
Also ensure that the revised certificati ons refer to the Form 10-Q/A and are
currently dated.
  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.   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 Lippm ann, 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