CORRESP 1 filename1.txt SNELL & WILMER L.L.P. 600 Anton Boulevard Suite 1400 Costa Mesa, California 92626-7689 TELEPHONE: (714) 427-7000 FACSIMILE: (714) 427-7799 Mark R. Ziebell 714.427.7402 mziebell@swlaw.com July 31, 2008 VIA FEDERAL EXPRESS Division of Corporate Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Mail Stop 3561 Attn.: Ryan C. Milne, Accounting Branch Chief RE: PROTEO, INC. (THE "COMPANY") FORM 10-KSB FOR FISCAL YEAR ENDED DECEMBER 31, 2007 FILE NO. 000-30728 Dear Mr. Milne: Reference is made to the letter dated July 21, 2008 from the Securities Exchange Commission (the "Commission"), in which the Commission commented that the Company does not appear to have disclosed its conclusion with respect to its evaluation of internal control over financial reporting as required by Item 308T(a)(3) of Regulation SB. The Company notes the Commission's comment and has revised its disclosure in Item 8A(T) of if Form 10-KSB for the fiscal year ended December 31, 2007 to include its conclusion with respect to its evaluation of internal control over financial reporting. For your reference, enclosed please find a copy of Amendment No. 1 to the Company's Form 10-KSB/A for the fiscal year ended December 31, 2007. The Company hereby acknowledges to the Commission the following: o the Company is responsible for the adequacy and accuracy of the disclosure in the filing; o 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 o 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. Mr. Ryan C. Milne July 31, 2008 Page 2 If you have any questions, please do not hesitate to give me a call at (714) 427-7402. Very truly yours, Snell & Wilmer /s/ MARK R. ZIEBELL Mark R. Ziebell MRZ:rp