SecProbe.io

July 9, 2012

Via Email
Pedro Perez Niklitschek President PN Med Group Inc. San Isidro 250, depot 618 Santiago, Chile 8240400
Re: PN Med Group Inc.
  Amendment No. 3 to Registra tion Statement on Form S-1
Filed July 2, 2012
  File No. 333-181229

Dear Mr. Niklitschek:
 We have reviewed your registration statem ent and have the following comments.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe  our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.
Use of Proceeds, page 9

1. We note your response to comment 2 in our lett er dated June 25, 2012, and we reissue, in
part, the comment.   We continue to note that  you will allocate your proceeds pro rata to
the uses described in each of the scenarios de scribed in the Use of Proceeds table.  As
written, this disclosure remains inconsistent  with the remainder of your use of proceeds
section because it appears that  you have allocated a fixed am ount to pay for legal and
professional fees as well as advertising expens es.  Please revise to clarify your disclosure
or remove the reference to the pro rata use of proceeds in each offering scenario.  Given
that you intend to implement your plan of opera tions regardless of the funds raised in the
offering, please describe how your proceeds will be allocated if you raise less than
$25,000.

Pedro Perez Niklitschek
PN Med Group Inc. July 9, 2012 Page 2
 2. We note your response to comment 3 in our le tter dated June 25, 2012, and we reissue the
comment.  Despite your response, we con tinue to note your st atement under the $25,000
category that your car column will include car rental and purchase based on the sale of
25%, 50%, 75% and 100% of th e securities offered by the Company.  Please advise or
revise.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Notwithstanding our comments, in the event you request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:
 should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.

Pedro Perez Niklitschek
PN Med Group Inc. July 9, 2012 Page 3
 You may contact James Giug liano at (202) 551-3319 or Br ian Bhandari at (202) 551-
3390 if you have questions regarding comments on th e financial statements and related matters.
Please contact Adam F. Turk at (202) 551-3657 or Pamela Howell at (202) 551-3357 with any
other questions.
Sincerely,
   /s/ Pamela Howell  for
John Reynolds Assistant Director