Via Facsimile and U.S. Mail
Mail Stop 03-09


October 29, 2004

Mr. David Ellison
Chief Financial Officer
Applied Neurosolutions, Inc.
50 Lakeview Parkway, Suite 111
Vernon Hills, IL 60061

Re:	Applied Neurosolutions, Inc.
Form 8-K filed October 25, 2004
File No. 001-13835

Dear Mr. Ellison:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, we will consider your explanation
as to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  In some of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not 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 on any other aspect
of our review.  Feel free to call us at the telephone numbers listed
at the end of this letter.

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

2. Please revise your filing to state whether the former accountant
resigned, declined to stand for re-election or was dismissed, as
required by Item 304(a)(1)(i) of Regulation S-B.  It is not
sufficient to state that you decided to end your engagement of your
former accountant, as that wording is unclear.

3. In providing the disclosures required by Item 304(a)(1)(iv) of
Regulation S-K, please revise you filing to specifically address the
two most recent fiscal years and the subsequent interim period
through the date that the former accountant either resigned, declined
to stand for re-election, or was dismissed, as "in connection with
its audits" may not be sufficiently inclusive.

4. Please file a letter from the former accountant addressing the
revised disclosures.

Please file your supplemental response and amendment via EDGAR in
response to these comments within 5 business days of the date of this
letter.  Please note that if you require longer than 5 business days
to respond, you should contact the staff immediately to request
additional time.  Direct any questions regarding the above to me at
(202) 942-2902.


							Sincerely,


							Oscar M. Young, Jr.
							Staff Accountant
Mr. David Ellison
Applied Neurosolutions, Inc.
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