Advanced Refractive Technologies, Inc. – ‘CORRESP’ from 4/4/07

On:  Wednesday, 4/4/07, at 2:04pm ET   ·   Private-to-Public:  Filing ¶  –  Release Delayed to:  6/1/07   ·   Accession #:  1019687-7-976

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Delayed-Release Comment-Response or Other Letter to the SEC
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: CORRESP     Comment-Response or Other Letter to the SEC            1      6K 

CORRESP
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[ADVANCED REFRACTIVE TECHNOLOGIES letterhead] 

APRIL 4, 2007                                                                   

Raquel Howard                                                                   
Staff Accountant                                                                
Securities and Exchange Commission                                              
Washington, D.C. 20549                                                          

Dear Ms. Howard:                                                                

In response to your letter dated March 8, 2007, pertaining to the filing of our 
8-K and the quarterly 10-Q's for 2006, I would like to acknowledge that:        

The company is responsible for the adequacy and accuracy of all the disclosures 
in the filings;                                                                 

Staff comments or changes to disclosures in response to staff comments do not   
foreclose the Commission from taking any action with respect to the filings;    

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

We are expecting the new independent accountant to be engaged by the middle of  
April and the financial statements for each period will be the first job for    
them to take care of and than we will immediately file re-amended returns.      

If you have any questions, please feel free to call me at 949-940-1300, ext.    
329.                                                                            

Sincerely,                                                                      

/s/ Laurence Schreiber                                                          

Laurence Schreiber                                                              
COO                                                                             

1062 Calle Negocio Suite D                             Phone: 949-940-1300      
San Clemente, CA 92673                                 Fax: 949-940-1301 (Main) 
U.S.A.                                                                          

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘CORRESP’ Filing		Date		Other Filings
Release Delayed to:		6/1/07		UPLOAD
Filed on:		4/4/07
		3/8/07		UPLOAD
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