June 6, 2005

Mail Stop 0610

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

      Re:	Advanced ID Corporation
		Amended Preliminary Proxy Statement on Schedule 14A
      Filed May 19, 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 provide all of the disclosures required by Item 7 of
Regulation 14A, including the following:

* The information regarding the company`s director nomination
process
required by Item 7(d)(2)(ii).  Please note that the term
"nominating
committee" refers to any body performing the functions of a
nominating committee, including the entire board of directors.

* The disclosures regarding board member attendance at annual
meetings required by Item 7(h)(3).

Information About Directors and Executive Officers

The Executive Officers

2. Please tell us why Bill Hoffman, as Vice President of Business
Development, has not been included as an executive officer.

3. Please revise to include a summary of the material terms of the
employment agreements with each of your executive officers.

Discussion of Proposals by the Board

Proposal 1:  Election of Directors

4. Please tell us why cumulative voting is not required under
Article
17, Section 5 of the South Dakota Constitution.  If cumulative
voting
is permitted, please revise to provide appropriate disclosure
regarding the nature, procedures for exercise and effect of those
cumulative voting rights.

Proposal 3:  Change Domicile to Nevada

5. We note your response to comment 12, including your statement
that
the change in domicile to Nevada "will be accomplished by
completing
the requisite documentation" and "will not be accomplished through
a
merger or acquisition..."  Please revise to further clarify how
the
change in domicile will be accomplished.  For example, since a
South
Dakota corporation and a Nevada corporation are separate and
distinct
legal entities, it is unclear how a South Dakota corporation can
become a Nevada corporation simply by completing "the requisite
documentation."

6. We note your response to comment 13, including your statement
that
you have not included copies of the Nevada charter and bylaws as
appendices to the proxy statement because you have not drafted
those
documents.  Please tell us supplementally why you believe
shareholders will have sufficient information to make an informed
voting decision with respect to the change in domicile to Nevada
when
the material provisions to be included in those documents have not
yet been determined.

7. We note your response to comment 14.  Please revise to include
a
discussion of all provisions of the South Dakota corporation`s
charter and bylaws that may have material anti-takeover effects
and
the extent to which, if at all, those provisions will differ from
those to be included in the charter and bylaws of the Nevada
corporation.

8. We note your response to comment 16.  Please revise to discuss
any
material federal income tax consequences to shareholders
associated
with the change in domicile from South Dakota to Nevada.

*  *  *  *

      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.

      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
June 6, 2005
Page 1