May 6, 2005

Mail Stop 0306

Barry Bennett
Chief Executive Officer
Advanced ID Corporation
6143-4 Street SE, Suite 14
Calgary, Alberta
Canada T2H 2H9

      Re:	Advanced ID Corporation
		Preliminary Proxy Statement on Schedule 14A
      Filed April 13, 2005
      File No. 0-24965

Dear Mr. Bennett:

	This is to advise you that we have reviewed only the
narrative
portions of the above filing and have not conducted an accounting
review of any of your company`s financial statements.  We have the
following comments on your filing.  We anticipate at this time
that
no further review of your proxy statement will be made other than
a
review of your responses to these comments.  Note that we may have
further comments on these issues.  All persons who are by statute
responsible for the adequacy and accuracy of the filing are urged
to
be certain that all required information has been included.

	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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

General

1. Please supplementally confirm to us, if true, that an annual
report to security holders of Advanced ID will be precede or
accompany the delivery of the proxy statement as required by Rule
14a-3(b) of Regulation 14A.

2. On the first page of the proxy statement as delivered to
security
holders, please state the approximate date on which the proxy
statement and form of proxy will be first sent or given to
security
holders.  Refer to Item 1(b) of Schedule 14A.

3. Please revise to include all of the information required by
Item
7(b), (c), (d), (f) and (h) of Schedule 14A.

4. Please revise where appropriate to discuss the treatment and
effect of abstentions and broker non-votes under applicable state
law
and under any applicable charter and bylaw provisions, as required
by
Item 21 of Schedule 14A.

Information About the Annual Meeting and Voting

How Do I Vote the Proxy?

5. We note your statement that the proxy card must be sent to you
"in
time," but it is unclear from your disclosure or the proxy card
when
the proxy card must be received.  Please revise to clarify.

May I Revoke My Proxy?

6. We note that a stockholder may revoke his or her proxy prior to
the voting by notifying the Secretary in writing.  Please revise
to
state whether a particular revocation form is required and also
how
soon before voting occurs must the Secretary receive the
revocation
notice.  Please also include the address to which revocations of
proxies or later dated proxies should be sent.

Which Stockholders own at least 5% of Advanced ID`s Common Stock?

7. Please revise to include the text associated with the footnotes
included in the table.

Information About Directors and Executive Officers

Compensation of the Board of Directors

8. Please provide the disclosures required by Item 402(f) of
Regulation S-B with respect to the stock options and shares of
restricted stock granted to directors.

How We Compensate Executive Officers

9. Please revise to provide all of the disclosures regarding the
compensation of your executive officers required by Item 402 of
Regulation S-B, including information regarding option grants made
during the past year, options exercised during the past year and
employment or change of control agreements with executive
officers.

Discussion of Proposals by the Board

Proposal 1:  Election of Directors

10. Please revise to clarify the vote required for the election of
each director.  For example, is approval required by the
affirmative
vote of a majority of the outstanding shares or by the affirmative
vote of a majority of the shares voted at the annual meeting?
Please
also clarify, if true, that the election of each director must be
approved by shareholders holding the requisite number of shares.

Proposal 2:  Re-Appointment of Auditors

11. Please provide the disclosures required by Item 9(c) and (e)
of
Schedule 14A.  In addition, if shareholder approval of the
appointment of the company`s auditors is not required, please also
provide the disclosures required by Item 18 of Schedule 14A.

Proposal 3:  Change Domicile to Nevada

12. Please revise to provide a brief summary of the material terms
of
the transaction by which the company will change its domicile from
South Dakota to Nevada.  For example, will the change in domicile
be
accomplished through a merger?  Are there conditions precedent to
the
completion of the change in domicile that need to be satisfied
other
than shareholder approval?

13. Please revise to provide a chart illustrating the material
differences between the rights of security holders of the South
Dakota corporation and the rights of security holders of the
Nevada
corporation.  Please also include copies of the charter and bylaws
of
the Nevada corporation as appendices to your proxy statement.

14. Please revise to present the material corporate governance and
control-related provisions intended to be effected by the proposed
reincorporation from South Dakota to Nevada as separate proposals
or
tell us supplementally why separate approval of each of those
provisions should not be required.  Refer to the Fifth Supplement
to
our manual of Publicly Available Telephone Interpretations
(September
2004).  Ensure that the discussion of each proposal presented
separately in response to this comment includes the disclosures
required by Item 19 of Schedule 14A and fully conforms with the
guidelines set forth in SEC Release No. 34-15230 (October 13,
1978),
Disclosure in Proxy or Information Statements; Anti-Takeover or
Similar Proposals.  Those disclosures should include, but not be
limited to, a discussion of:
* The effects on stockholders from an anti-takeover perspective;
* Whether the proposal is submitted as a result of or in response
to
any accumulation of stock or threatened takeover;
* Whether you have any plans to subsequently implement additional
measures having anti-takeover effects; and
* Existing provisions of the certificate of incorporation, bylaws
and
agreements which have material anti-takeover effects.

15. Disclose in greater detail the reasons for the change in
domicile
and the effect of the change on the rights of shareholders.

16. Please include a discussion of any material federal income tax
consequences to the company or to shareholders associated with the
change in domicile from South Dakota to Nevada.

Proposal 4:  Reverse Stock Split

17. Please revise to explain why you are proposing a reverse stock
split of not less than one-for-three shares and not more than one-
for-eight shares, particularly given that even a one-for-eight
share
reverse stock split would not appear to result in your current
trading price falling within the desired $3.00 to $4.00 per share
range.

18. Please revise to identify a limited number of specific
alternative ratios upon which the board of directors may implement
the reverse stock split rather than a range of possible ratios.

19. Please revise to identify the factors that will be considered
by
the board in determining which of the alternative ratios will be
selected should the board determine to implement a reverse stock
split.

20. Please revise to clarify, if true, that a reverse stock split
will be effected, if at all, only upon a determination by the
board
of directors that a reverse stock split (with a ratio selected by
the
board from one of the specified alternative ratios based on the
factors described in the filing) is in the best interests of the
company and its shareholders.

21. Please revise to identify the latest date by which the reverse
stock split would be completed.

22. Please revise to clarify the effect, if any, that the
implementation of the reverse stock split will have on the number
of
authorized shares of the company.  If the reverse stock split will
have the same effect as an increase in the number of authorized
shares, please also include disclosures substantially similar to
those that would be required if the company was separately
proposing
to increase its number of authorized shares.

23. Please revise to disclose, if true, that you currently satisfy
all of the listing requirements of the American Stock Exchange and
the Nasdaq National Market or the Nasdaq Small Cap Market, as
applicable, other than the minimum share price.  Alternatively,
please identify the other criteria that you do not expect to
satisfy,
discuss how you intend to address those deficiencies, and explain
in
the filing why you are seeking approval for the reverse stock
split
at this time given those deficiencies.

24. Please revise to address the treatment of fractional shares in
connection with the reverse stock split proposal.  For example,
will
cash be paid for fractional shares?  In addition, if fractional
shares will be eliminated and the elimination of fractional shares
will materially affect the percentage ownership of the company by
its
officers, directors and affiliates, please include appropriate
disclosure.

25. Please include a discussion of any material federal income tax
consequences to the company or to shareholders associated with the
reverse stock split.

About Stockholder Proposals

26. Please revise to identify the specific date after which
shareholder proposals submitted outside of Rule 14a-8 will be
considered untimely.  Refer to Rule 14a-5(e)(2) of the Exchange
Act.

Proxy Card

27. Please revise to clarify the meaning of your statement that
"[t]his proxy may be exercised by a majority of those proxies or
their substitutes who attend the meeting," particularly given that
only one person has been named as a proxy on the proxy card.

28. In future filings on Schedule 14A, including amendments to
this
preliminary proxy statement, please include the proxy card as an
appendix to the proxy statement rather than immediately following
the
facing page.  Refer to the note to paragraph (a)(3) of Rule 14a-4
of
the Exchange Act.

*  *  *  *

      As appropriate, please revise your proxy statement in
response
to these comments and to update your disclosure.  As required by
Rule
14a-6(h), please provide us with marked copies of the revised
proxy
statement to expedite our review.  Please furnish a cover letter
with
your revised proxy statement that keys your responses to our
comments
and provides any requested supplemental information.  Detailed
cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your revised proxy
statement
and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  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 filing;

* staff comments or changes to disclosure in response to staff
comments 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.

      Please contact the undersigned at (202) 942-7924 with any
questions.
Sincerely,



David Ritenour
Special Counsel

cc (via fax):	Jody Walker, Esq.
      (fax: 303-220-9902)
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Advanced ID Corporation
May 6, 2005
Page 1