Mail Stop 6010

      August 18, 2005



Mr. John Cousins
Chief Financial Officer
Advanced Optics Electronics, Inc.
8301 Washington NE
Suite 5
Albuquerque, New Mexico 87113

	RE:	Advanced Optics Electronics, Inc.
		Form 10-KSB for the fiscal year ended December 31, 2004
		Filed April 04, 2005
		Form 10-QSB for the quarter ended March 31, 2005
		Form 10-QSB for the quarter ended June 30, 2005
		File No. 000-24511

Dear Mr. John Cousin:

      We have reviewed your response to our letter dated July 29,
2005 and have the following 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 year December 31, 2004

General

1. File the amended Form 10-KSB referred to in your cover letter.


Results of Continuing Operations

Operating Expenses, page 19

2. We refer to your response to comment 6.  Please provide us
schedules of the underlying calculations of the gains and losses
on
the debenture conversions.  Provide explanation about how you
determined the amounts presented on those schedules. Show us how
you
measured the fair value of the stock issued in satisfaction of the
notes.  If you used other than the quoted market price of the
shares
on the conversion dates, explain why your method conforms to GAAP.


Form 10-Q as of June 30, 2005

Statements of Cash Flows, page F-4

3. Disclosure on page F-9 indicates that you transferred to
consultants approximately 14.5 million shares of Genomed stock
with a
fair value of $390,366.  Tell us why the operating section of the
cash flow statement does not present a non-cash charge for the
fair
value of the shares transferred.  Either revise or explain why
your
presentation is appropriate under SFAS 95.

4. As a related matter, confirm that the $293,347 identified as
"Investment in Genomed" is an actual cash sale.  If these shares
were
not sold for cash, either appropriately revise the cash flow
statement or explain why the existing presentation is appropriate
under SFAS 95.

5. Provide us roll-forwards from December 31, 2004 to June 30,
2005
of the number of Genomed shares and the fair value of those
shares.
Present transactions and changes in fair value in gross amounts by
quarter.



Note 8, Stockholders` Equity, page F-15

6. You disclose that during the six months ended June 30, 2005 you
issued 21 million shares for debentures.  Show us how you measured
the $21,000 fair value assigned to those shares. If you used other
than the quoted market price of the shares on the conversion
dates,
explain why your method conforms to GAAP.


Item 3, Controls and Procedures, page 10

7. You disclose that your controls and procedures are of limited
effectiveness.  Under Item 307 to Regulation S-B you should
express a
clear and unequivocal opinion about the effectiveness of
disclosure
controls and procedures.  That is, you may state that disclosure
controls and procedures are effective or you may state that
disclosure controls and procedures are not effective.  If you
conclude that such controls and procedures are not effective you
should also provide appropriate explanation.

8. We see that the Chief Executive Officer and Chief Financial
Officer evaluated disclosure controls and procedures as of a date
within 90 days before the filing date of the quarterly report.
Amend
to disclose management`s conclusion regarding the effectiveness of
disclosure controls and procedures as of the end of the period
covered by the quarterly 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).

















      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 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.

      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. John Cousin
Advanced Optics Electronics, Inc.
August 18, 2005
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