A PROFESSIONAL CORPORATION   3 Triad Center Suite 500 Salt Lake City, Utah 84180   T  : (801) 532-7080 F  : (801) 596-1508   www.strongandhanni.com GLENN C. HANNI, P.C. HENRY E. HEATH PHILIP R. FISHLER ROGER H. BULLOCK R. SCOTT WILLIAMS SCOTT R. JENKINS PAUL M. BELNAP STUART H. SCHULTZ BRIAN C. JOHNSON 2 PAUL W. HESS STEPHEN J. TRAYNER STANFORD P. FITTS 7 BRADLEY W. BOWEN PETER H. CHRISTENSEN 5 ROBERT L. JANICKI H. BURT RINGWOOD CATHERINE M. LARSON KRISTIN A. VANORMAN PETER H. BARLOW GRADEN P. JACKSON 3 H. SCOTT JACOBSON MICHAEL J. MILLER 6 ANDREW D. WRIGHT MICHAEL L. FORD 4 BYRON G. MARTIN BENJAMIN P. THOMAS SUZETTE H. GOUCHER JACOB C. BRIEM  1 LANCE H. LOCKE A. JOSEPH SANO JAMES C. THOMPSON PETER J. BAXTER JENNIFER R. CARRIZAL LORI A. JACKSON BRYANT J. McCONKIE WILLIAM B. INGRAM JEREMY G. KNIGHT RYAN P. ATKINSON JARED T. HALES JEFFERY J. OWENS ANDREW B. McDANIEL SADÉ A. TURNER AREK E. BUTLER PAUL W. JONES 1 ALSO MEMBER ARIZONA BAR 2 ALSO MEMBER CALIFORNIA BAR 3 ALSO MEMBER COLORADO BAR 4 ALSO MEMBER DISTRICT OF COLUMBIA BAR 5 ALSO MEMBER OREGON BAR 6 ALSO MEMBER WASHINGTON BAR 7 ALSO MEMBER WYOMING BAR                  ESTABLISHED 1888                          ______             GORDON R. STRONG                       (1909-1969)  

August 11, 2008

Christine Davis

Assistant Chief Accountant

Securities and Exchange Commission

Washington, DC 20549

RE:          InMedica Development Corporation

Form 10-K/A1 for Fiscal Year Ended December 31, 2007

File No. 000-12968

Dear Ms. Davis:

InMedica Development Corporation (“InMedica” or the “Company”) has amended its Form 10K for the year ended December 31, 2007 concurrently with this correspondence filing in response to your comment letter of July 21, 2008.   We respond below to the comments in your letter, setting forth each of your comments followed by the Company’s response:

SEC COMMENT:    10-K for Fiscal Year Ended December 31, 2007

Item 9A.  Controls and Procedures, page 11

1.   It does not appear that your management has performed its assessment of internal control over financial reporting as of December 31, 2007.  Since you were required to file or filed an annual report for the prior fiscal year, it appears you are required to report on your management’s assessment of internal control over financial reporting.

If your management has not yet performed its assessment, we ask that you complete your evaluation and amend your filing within 30 calendar days to provide the required management’s report on internal control over financial reporting. * * *

RESPONSE:   An amendment to the Company’s Report on form 10K has been filed that includes a copy of management’s report of assessment of internal control over financial reporting as described in the Form 10K/A1 for the year ended December 31, 2007, amending items 9A and  Exhibits.

Ms. Christine Davis

August 8, 2008

Page 2

SEC COMMENT:

2.   Please consider whether management’s failure to perform or complete its report on internal control over financial reporting impacts its conclusions regarding the effectiveness of your disclosure controls and procedures as of December 31, 2007 and revise your disclosure as appropriate.

RESPONSE:   See response to Comment One above.

SEC COMMENT:

3.   We note your disclosure that your disclosure controls and procedures “functioned effectively.”  However, it does not appear that your certifying officers have reached a conclusion that your disclosure controls and procedures are effective.  Please revise to provide a clear conclusion regarding the effectiveness of your disclosure controls and procedures.

RESPONSE:   The language of the Item and Management’s Report has been modified to clarify that the disclosure controls and procedures are effective.

SEC COMMENT:

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.

RESPONSE:   The requested statement of the Company is attached to this letter.

Very truly yours,

STRONG & HANNI, P.C.

/s/ Scott R. Jenkins

Scott R. Jenkins