SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE
      January 8, 2010
 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. 5 to Registra tion Statement on Form 10
Filed on December 23, 2009
File No. 0-53497
 Dear Mr. Katzaroff:    We have reviewed your filing and have the following additional comments.  Where indicated, we think you shoul d revise your documents in response to
these comments.  If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unneces sary.  Please be as detailed as necessary
in your explanation.  In some of our comme nts, we may ask you to provide us with
supplemental information so we may better understand your disclosure.  After 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.

Registration Statement on Form 10

Index to Exhibits, page 38
1.     Footnotes 1 and 2 to the index should be revised to state that the exhibits were
“previously filed” with the Form 10 filed on November 12, 2008 and with the
Form 10/A filed on “February 7, 2009, resp ectively.  As currently presented, you
are incorporating exhibits into the same filing.  Please revise.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
January 8, 2010 Page 2

Form 10-Q for the Period Ended September 30, 2009

2. Regarding comment 1 from our letter dated September 11, 2009 and comment 4
from our letter dated July 10, 2009, we not e that in your response of August 21,
2009, you state you modified your growth and operating plans such that only $1
million would be needed to fund your operati ons for an additional year.  You have
amended your Form 10 to include this information.  However, note 2 to the
financial statements in your Form 10 -Q dated September 30, 2009 states again
that you need $3 million to continue opera tions for the next 12 months, while
your liquidity section of MD&A states th at $1 million is needed.  Please amend
your Form 10-Q to clarify what your liqui dity needs are in order to continue
operations in the short term and long term.  Make sure that the disclosure in the
notes to your financial statements and MD &A are consistent.  Further, discuss
how you have modified your growth and ope rating plans in order to ensure your
continued operations.  We may have additional comments upon review of your response.
3. We note that in several places in your September 30  Form 10-Q, you refer to a
quarter or nine months ended June 30, 2009 instead of September 30, 2009.  For example, your Liquidity and Capital Resour ces section of MD&A refers to “nine
month periods ending June 30, 2009 and J une 30, 2008”, and in your discussion
of changes in internal control over fi nancial reporting on page 29, you refer to
“the quarter ended June 30, 2009”.  Other examples of this type of error may
appear elsewhere in the Form 10-Q.  Pleas e review and revise these references in
an amended Form 10-Q.
   Please respond to these comments with in 10 business days, or tell us when you
will provide us with a response.  Please provi de 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.   We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information required under the Securities Exch ange of 1934 and that they have provided
all information investors require for an in formed decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy  of the disclosures they have made.

In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation January 8, 2010 Page 3

• the company is responsible for the adequacy and accuracy of the disclosure in
the filing;

• 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.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.
  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 me at (202) 551-3766 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