Mail Stop 0306

May 24, 2005


By U.S. Mail and facsimile to (403) 263-2055


Mr. Todd Noble
Chief Financial Officer
Advanced ID Corporation
6143 - 4 Street SE, Suite 14
Calgary, Alberta, Canada T2H 2H9

	RE:	Advance ID Corporation
		Form 10-KSB for the year ended December 31, 2004
		Form 10-QSB for the quarter ended March 31, 2005
      File No. 000-24965

Dear Mr. Noble:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  Where indicated, we think you should revise your
document
in future filings in response to these comments.  If you disagree,
we
will consider your explanation as to why our comment is
inapplicable
or a revision is unnecessary.  Please be as detailed as necessary
in
your explanation.  In some of our comments, 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 review 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.



Form 10-KSB for the fiscal year December 31, 2004

Item 6.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations - Pages 16-18

Critical Accounting Policies and Estimates
1. Revise future filings to provide critical accounting policy
disclosure. For guidance about this disclosure refer to FR-60 and
FR-
72.

Results of Operations - Page 16
2. Under cost of revenues, disclose gross margin (or cost of
revenue)
as a percentage of sales and explain reasons for changes in this
important ratio from period to period. Apply in all future
filings.

Financial Statements

Report of Independent Registered Public Accounting Firm - Page 19
3. You disclose on page 18 that existing cash balances are
expected
to be sufficient to fund current operations over the next seven to
ten months.  You also disclose that you have no firm commitments
for
future financing.  Based on your disclosures, it is not clear that
you have the ability to continue as a going concern as defined in
AU
Section 341. In a supplemental narrative, tell us why the audit
report should not be modified to include going concern disclosure.
Be
detailed and specific in support of your conclusion.  The response
should clearly layout your consideration of the guidance from AU
Section 341.

Balance Sheet - Page 20
4. It appears that you do not have $25 million in accounts
receivable. Accordingly, the balance sheet appears to include a
material typographical error. We also see that one other asset has
no
caption title. Please amend to correct these errors.

Note 1- Business and Summary of Significant Accounting Policies -
Page 24

	Revenue Recognition - Page 24
5. It appears that you provide products and continuing services.
We
see that you sell tags, readers and related software; and, we see
that you provide database and tracking services.  Your disclosed
revenue policy suggests that all of the underlying revenue is
allocated to the product without allocation or deferral for
service
commitments or obligations.  In a detailed supplemental narrative,
fully describe the terms and conditions of your product sales and
describe the nature, extent and terms of the related services.
Explain why you believe your revenue policy complies with GAAP.
That
response should clearly and specifically explain why revenue
should
not be allocated or deferred with respect to services and should
support that position in GAAP, including SAB 104. You should
identify
the literature on which you based your accounting and explain how
you
interpreted and applied that literature. Respond separately for
the
Companion Animal/Biological Sciences and Livestock businesses. We
may
have further comment on your revenue practices and related
disclosure
once we better understand the bases for your policies.

6. With respect to product sales with accompanying tracking and
database services, explain your consideration of Question 2 to SAB
Topic 13A.3.f.  For instance, it would appear that customers would
not likely purchase companion animal products without the
continuing
services. Why is this guidance not applicable in your
circumstances?

7. You disclose on page 7 that you have relationships with
distribution agencies in Canada.  In a supplemental narrative,
tell
us about the terms and conditions of sales to these entities and
support that the timing of revenue is appropriate for transactions
with these entities.  Support in GAAP that it is appropriate to
recognize revenue before the product has been resold to an end
user
or installed in an animal.

8. Tell us about the nature and extent of post shipment
obligations
(installation, training, upgrades, future services, etc...) and
customer acceptance protocols.  Tell us how these matters are
considered in your revenue practices.  Also respond with respect
to
return policies and practices.

9. We see from disclosure under Recent Developments (page 8) that
you
appear to have made shipments of RFID products for field trial or
evaluation purposes. Tell us how you accounted for these
shipments.
If revenue was recognized, support in GAAP that the accounting is
appropriate. Refer to SAB 104 for guidance.

10. In a supplemental narrative, tell us why the guidance from
EITF
00-21 does not apply to your revenues.  We see, for instance, that
the companion animal business appears to involve both products and
services.

Stock Options - Page 26
11. We see that you granted more than 1 million stock options in
April 2004 while the pro forma impact of fair value accounting is
the
same amount in both 2003 and 2004.  Accordingly, it is not clear
whether the pro forma disclosure for 2004 is properly prepared.
Tell
us how you accounted for options granted in 2004 in preparing the
SFAS 123 pro forma disclosure.  The supplemental narrative should
show us that you properly applied the requirements of SFAS 123 in
fulfilling the pro forma disclosure requirement.  Revise the
disclosure if necessary.


Note 2 - Common Stock - Page 27
12. Future filings should clarify how you determined the 18%
discount
rate for the convertible note.  You should also present detail
about
how you measured and accounted for the beneficial conversion
feature.
That is, future disclosure should clarify how you applied EITF 98-
5
and EITF 00-27.  Combined, future filings should present clear
disclosure about how you measured both components of the $969,000
charge.

Note 4 - Commitments - Page 29
13. Unless insignificant, please expand future filings to present
qualitative and quantitative disclosure about product warranties.
Refer to FIN 45 for guidance.

Note 5 - Stock Options and Warrants - Page 30
14. Future filings should provide a roll-forward of option
activity
for each income statement period.  You should also present grant
date
fair value disclosure for each income statement period.  Refer to
SFAS 123.


Reportable Segments
15. We see disclosure about revenues from sales outside Canada.
Future filings should present geographic disclosure about revenues
as
set forth in paragraph 38 to SFAS 131.

Item 8A. Controls and Procedures - Page 33
16. You disclose that the Principal Executive Officer and
Principal
Financial Officer evaluated disclosure controls and procedures as
of
a date within 90 days of the filing date of the annual report.
Revise future filings, including Forms 10-QSB, to disclose
management`s conclusion regarding the effectiveness of disclosure
controls and procedures as of the end of the period covered by the
report. Refer to Item 307 of Regulation S-B and Part II.F of
Management`s Reports on Internal Control Over Financial Reporting
and
Certification of Disclosure in Exchange Act Periodic Reports,
Release
No. 33-8238, available on our website at
www.sec.gov/rules/final/33-
8238.htm.
17. Please also note that the references to Rules 13a-14(c) and
15d-
14(c) were superseded in 2003.  Future filings, including Forms
10-
QSB, should be updated to reflect the Rule references from Item
307
to Regulation S-B.
18. In future filings, including Forms 10-QSB, please revise to
indicate whether there was any change to internal control over
financial reporting that has materially affected, or that is
reasonably likely to materially affect, internal control over
financial reporting. Refer to the language used in amended Item
308(c) of Regulation S-B.

Section 302 Certification - Exhibit 31 - Pages 40 and 41
19. We see numerous differences between the language in your
certifications and the required language as set forth in Item
601(b)(31) to Regulation S-B. The certifications must be in the
exact
form prescribed; and the wording of the required certifications
may
not be changed in any respect, except for the modifications
temporarily permitted to be made to the fourth paragraph pursuant
to
Part III.E of Release No. 8238. Accordingly, please file an
amendment
to your Form 10-KSB that includes the entire filing together with
the
certifications of each of your current CEO and CFO in the form
currently set forth in Item 601(b)(31) of Regulation S-B. The Form
10-QSB for the quarter ended March 31, 2005 should be similarly
amended for this matter.


*    *    *    *


      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comments and provides any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR.  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 investors require.
Since the company and its management are in possession of all
facts
relating 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

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* 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.


      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Patrick Enunwaonye, Staff Accountant, at
(202)
551-3645 or me, at (202) 551-3605 if you have questions regarding
comments on the financial statements and related matters. In this
regard, do not hesitate to contact Brian Cascio,  Accounting
Branch
Chief , at (202) 551-3676 with any other concerns.



							Sincerely,


							Gary Todd
							Review Accountant
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Mr. Todd Noble
Advanced ID Corporation
May 24, 2005
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