Mail Stop 6010


      March 8, 2006


Via U.S. Mail and Facsimile to (303) 592-1054

Kristi J. Kampmann
Chief Financial Officer
Vyta Corporation
370 17th Street, Suite 3640
Denver, CO 80202


	Re:	Vyta Corporation
		Form 10-QSB for the Fiscal Quarter Ended December 31,
2005
		Filed February 21, 2006
      File No. 033-19598

Dear Ms. Kampmann:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  In some of our comments, we may ask
you
to provide us with information so we may better understand your
disclosure.  After reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.









Form 10-QSB for the Fiscal Quarter Ended December 31, 2005

Item 1. Financial Statements (Unaudited)

1. Business, Organization and Summary of Significant Accounting
Policies, page F-8

Recent Developments, page F-9

1. We see that you have entered into various loans, subscription
agreements and other arrangements with Arizcan, including, but not
limited to, a loan of $314,000 in November of 2004 to facilitate
their purchase of your outstanding stock warrants, an agreement to
pay them 20% of any cash distributions paid to you by and from
BioAgra until they are paid $800,000 for their efforts to assist
you
in obtaining equity financing, a subscription agreement to
purchase
200,000 shares of convertible preferred stock for a partial
payment
of $400,000 cash and an unsecured note receivable the subsequent
conversion of which resulted in them obtaining a controlling 67%
interest in your common stock. Please address the following:

* tell us in detail the business purposes of each of these
transactions individually and in the aggregate;
* confirm that these are the only transactions with Arizcan in the
periods presented or alternatively detail for us all other
transactions. Additionally, please detail for us the relationship
of
Arizcan to you prior to these transactions, including whether
Arizcan
or any members of their board of directors or management was a
related party as defined by SFAS 57;
* confirm that all transactions with Arizcan were consummated on
terms equivalent to those that prevail in arm`s-length
transactions;
and
* confirm that in future filings you will present any receivables
that arise in connection with sales of your equity instruments in
compliance with                      EITF 85-1.

 We may have further comment based on your response.

3. Investments in Affiliates, page F-13

Investment in BioAgra, page F-14

2. We note that on August 15, 2005, you purchased a 50% equity
interest in BioAgra, a joint venture with Xact Resources, through
the
contribution of cash and a note payable. We see on page F-12 that
subsequent to the formation of the joint venture, you have also
loaned BioAgra an additional $700,000. Please tell us how you
assessed and concluded that you do not hold a variable interest in
BioAgra and are not the primary beneficiary for purposes of FIN
46R.
Please reference the applicable sections of FIN 46R you used to
make
your conclusions, including the one that consolidation of BioAgra
was
not required.  We may have further comments after reviewing your
response.

4. Note and Advances Payable, page F-16

3. We see various transactions whereby you received loans from
unrelated third parties in consideration for a promissory note and
the issuance of restricted common stock which in aggregate
exceeded
the value of the cash received. We also note that the loans were
subsequently repaid within three months of their issuance. You
determined that the loan proceeds should be allocated between to
the
relative fair value of the promissory note and the common shares,
with the relative fair value of common shares recorded as a
discount
to the note and amortized to interest expense. Please tell us the
authoritative generally accepted accounting principles that
support
your accounting and presentation of these transactions, including
specific references to the technical accounting literature which
supports your conclusions. We may have further comments after
reviewing your response.

5. Derivative Warrant Liability, page F-17

4. We note that you have concluded the various warrants issued
during
December of 2005 were derivative liabilities upon their issuance
due
in part to an insufficient number of authorized and unissued
shares.
We also note subsequent to a reverse stock split, the fair values
of
the warrants were reclassified to equity.  Please tell us the
significant terms of the warrants including detail of any
registration rights, requirements to maintain effectiveness of a
registration statement or penalties associated with the underlying
shares of the warrants and how you accounted for each.  Tell us
how
your initial and subsequent accounting and presentation for the
warrants complied with generally accepted accounting principles.
Also, tell us why you believe you assigned the correct value to
the
warrants.  That is, tell us why you recorded the warrants at their
relative fair value rather than their fair value.  Refer to SFAS
129,
EITF 00-19 and EITF 05-04 when preparing your response.  We may
have
further comments after reviewing your response.

	As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and 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.

      You may contact Kevin Kuhar, Staff Accountant, at (202) 551-
3662 or me at (202) 551-3603 if you have questions regarding these
comments on the financial statements and related matters.  In this
regard, do not hesitate to contact Angela Crane, Branch Chief, at
(202) 551-3554.




								Sincerely,



								Jay Webb
								Reviewing Accountant

Kristi J. Kampmann
Vyta Corporation
March 8, 2006
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