Via Facsimile and U.S. Mail
Mail Stop 6010


							June 14, 2005


James H. Chamberlain
Chef Executive Officer, Chief Financial Officer and Director
Xtrana, Inc.
P.O. Box 668
Sedalia, Colorado 80135

Re:	Xtrana, Inc.
	Registration Statement on Schedule 14A
	Filed May 16, 2005
	File Number 001-14257

	Form 10-K for the year ended December 31, 2004
	File No. 001-14257

Dear Mr. Chamberlain:

	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.


Schedule 14A

General

1. In your amended filing, update all information to the latest
date
practicable.

2. Please note that you are required to file with the Commission
any
written instructions, scripts, and outlines that will be used by
any
person that solicits proxies on behalf of Xtrana, Inc., through
personal interview, telephone, or telegram, and all other
soliciting
material that will be furnished to Xtrana stockholders.  See Rules
14a-6(b) and (c) of the Exchange Act of 1934.

3. Please describe the interests of your officers, directors and
any
relevant stockholders in any matter to be acted upon as required
by
Item 5 of Schedule 14A.  For example, please explain if any of
your
officers or directors have interests in your proposed reverse
acquisition of Alpha Innotech Corporation that are different from,
or
in addition to, the interests of the stockholders.

4. Please supplementally provide us with copies of your board
books
and any other materials prepared by the Mentor Group, Inc. that
were
provided to the board of directors, including drafts of fairness
opinions provided to the board of directors, and any summaries of
presentations made to the board of directors.  We may have further
comment on your disclosure once we have had the opportunity to
review
these materials.

5. You have indicated on page 51 that shareholders do not have
dissenter`s rights with respect to the amendment to the
Certificate
of Incorporation and the reverse stock split.  Please revise to
disclose that shareholders also do not have dissenter`s rights
with
respect to the merger, if accurate.  If they do have dissenter`s
rights with respect to the merger, please describe the statutory
procedure required to be followed by dissenting shareholders in
order
to perfect rights of appraisal.  This discussion should address
whether a shareholder`s failure to vote will constitute a waiver
of
appraisal rights.

6. Please provide us with an update on the status of obtaining a
permit from the California Department of Corporations.

Summary, page 1

7. Please revise the summary term sheet to include cross
references
to the more detailed disclosure in your document.


Proposal No. 1: Election of Directors, page 8

8. Please note that Item 401 of Regulation S-K requires a brief
description of the business experience of your officers and
directors
during each of the last five years.  Please revise this section to
include the applicable dates for James Chamberlain, Douglas Ayer,
and
James Mahony.

9. Please disclose whether you maintain a charter for the director
nomination process pursuant to Item 7 of Schedule 14A.  If so,
please
include a current copy of the charter as an appendix to the
preliminary proxy statement.  If not, please so state.


Proposal No. 2: The Merger, page 15

General

10. In addition, please disclose whether you have any plans to
issue
the common stock resulting from the reverse stock split other than
for issuance pursuant to the merger.  We may have further
comments.

Background of the Merger, page 15

11. Please revise to provide a detailed discussion of all meetings
held to discuss the search for a merger candidate and the merger
with
Alpha Innotech.  The discussion should address whether other
companies were considered, whether a search for a merger candidate
was conducted and if a search were conducted what the search
entailed.  The discussion of each meeting relating to the merger
with
Alpha Innotech should include information as to when the meeting
took
place, who initiated the contact, who was present, the issues were
discussed and any decisions that were made.   In accordance with
the
requirements of Instruction 7(b)(7) of Item 14 of Schedule 14A and
Item 1005(b) of Regulation M-A, you should describe in detail the
nature and substance of the deliberations conducted at meetings.
The
disclosure should provide shareholders with an understanding of
how,
when and why the terms of the proposed transaction evolved during
the
course of the board`s deliberations in the period beginning in
September 2004 and ending with the execution of the Agreement and
Plan of Merger in December 2004.  Broad generalizations about
topics
covered during these meetings are not sufficient.

12. We note your disclosure on page 21 that the Board identified
and
investigated a number of potential opportunities.  Please revise
this
discussion to provide more details about the other merger partners
that were considered.  You should include a brief description of
the
other candidates, whether there were any discussions or
negotiations
with these parties, and why you decided to pursue this merger
instead.  We may have further comments.
13. Please describe in reasonable detail how the consideration was
determined and negotiated.

14. Please explain why the board determined Aduromed Corporation
to
not be suitable as a target company for a merger.  Please describe
what specific factors on page 16 they failed to satisfy.

15. We note your statement that the Board of Directors determined
that Alpha Innotech met the criteria established by the Board of
Directors in its review of potential merger partners.  Is the
"criteria" that you refer to the same as the factors that are
disclosed in the paragraph preceding this statement?  Please
explain
how the Board determined that Alpha Innotech met these criteria.

16. Please expand your disclosure to explain the amendment to the
merger agreement.  Identify the provisions that were revised, the
effects of these revisions and the circumstances requiring the
revisions.

The Merger Agreement, page 16
17. Please revise your statement that the summary "does not
purport
to be complete" to clarify that it addresses all material terms of
the agreement and ensure that it does so.

18. Please revise the discussion of the loan from Alexandria to
identify the firm that arranged the financing.  Is this the party
that received a warrant to purchase 900,000 shares of common
stock?
If not, identify the party that received the warrant.  Disclose
the
compensation the firm received for arranging the financing.

19. Are there any circumstances under which Alpha Innotrec would
be
required to pay a termination fee?

Merger Consideration, page 21

20. Please explain why you have not included as part of the merger
consideration the cash delivery of approximately $2.2 million and
the
$500,000 advance pursuant to the merger agreement as disclosed on
page 23.  To the extent you have not included all terms and
provisions, please detail clearly all the consideration for the
transaction.  We may have further comments.

Board of Directors` Reasons for the Merger, page 21

21. Please balance the discussion of Xtrana`s reasons for the
transaction with a list of adverse factors that were considered.
Your brief reference to certain risks considered on page 22 is not
sufficient.  This discussion should address not only the
difficulties
associated with the acquisition agreement and integrating the
combined company, but also any issues regarding Alpha Innotech
itself
that Xtrana`s board considered to be adverse.
22. Please expand the factors considered by the board of Xtrana in
approving the Agreement and Plan of Merger to discuss each
itemized
factor in reasonable detail so that the reader understands the
board`s thought process.  Each of the material reasons for the
board`s decision, both positive and negative, should be expanded
so
that the reader understands the nature of the factors considered,
the
board`s conclusions and observations about such factors, and how
such
information influenced the board`s deliberations.  For example, to
be
meaningful for shareholders, the list of factors on page 16,
should
also discuss what conclusions the board reached about the two
companies` compatibility and how each factor weighed in favor of
approving the merger.
23. Please provide us supplementally with copies of any non-public
information - documents, financial forecasts, projections and
presentations - used by or on behalf of Xtrana in the merger
negotiations.  We may have additional comments.

Opinion of Financial Advisor to the Board of Directors, page 23

24. Please revise the discussion to ensure that the assumptions
made,
matters considered and limitations on the review undertaken are
disclosed in the proxy statement itself.

25. Please revise the statement in the fifth paragraph on page 24
that states that the opinion is for the sole use and benefit of
the
Board of Directors to clarify that the shareholders have a right
to
use the opinion.

26. We note your statement that you express no opinion regarding
the
liquidity value of any entity.  Please revise to explain why
Mentor
did not consider the liquidation value of Xtrana in rending the
fairness opinion.

27. Please specify how the Mentor Group selected the publicly
traded
companies that it deemed generally similar to Alpha Innotech for
purposes of its comparable company analysis.  What were the
criteria
used to make the selection?  If there were any companies that met
the
selection criteria that were excluded from the analysis, please
revise to explain why they were excluded.

28. Please explain the judgments and assumptions Mentor made with
respect to industry performance, general business, economic,
market
and financial conditions.

29. Is the NFY revenue a projection?  If so, explain how Mentor
calculated NFY for comparable companies.

30. Were the transactions selected the only transactions involving
target companies in the life sciences tools industry during the
last
five years?  If there were other transactions meeting these
criteria,
explain why those transactions were excluded from the analysis.

31. We note that for each revenue multiple calculated Mentor came
up
with a range and then selected a narrower range.  Please disclose
how
the Mentor Group selected the narrower range used to calculate an
enterprise value for Alpha Innotech.   Also, disclose how Mentor
selected discount rates used in its calculations.

32. Explain why Alpha Innotrech`s projections are not material and
are not required to be disclosed.  Supplementally, provide us with
copies of the forecasts of Alpha Innotech provided to the Mentor
Group.  We may have further comments.

33. In your discussion of the net asset approach, please explain
the
adjustments to the asset and liability values.

34. It is not clear how Mentor reached the conclusion that the
transaction was fair to the shareholders or Xtrana.  We note that
in
each of these analyses, you have calculated an enterprise value
for
Alpha Innotrech.  How did you conclude that the transaction was
fair
to the shareholders of Innotrech?  For example, did you compare
the
enterprise value of Innotrech to the market value of the
outstanding
shares of Xtrana or the net asset value of Xtrana?

Description of Xtrana Capital Stock, page 30

35. Please state the expiration date of the options, and state
whether the expiration date may be extended and, if so, how.

36. Please state whether the expiration date on the warrants may
be
extended and, if so, how.  Please also clarify whether the
warrants
are callable and, if so, how and when you could call the warrants.

Alpha Innotech Business and Financial Information, page 31

General

37. Please revise to provide a detailed discussion of your
products.
Your discussion should clarify which products are currently
available
and which products are under development.  For products under
development, indicate the stage of development.  As currently
written, the nature of Alpha Innotech`s business and products are
not
clear.  We may have further comments.

38. Please consider including a comprehensive risk factors section
of
Alpha Innotech`s business operations.

Overview, page 31

39. If they maintain a website, please disclose Alpha Innotech`s
URL.

Market Opportunity, page 31

40. Please quantify the size of Alpha Innotech`s target market.

Technology, page 31

41. Please revise to explain the nature of the technology covered
by
the patents.  Disclose the identity of the assignee and the
licensee.
Include a discussion of the material terms of the license and
assignment agreements.

42. Please disclose the expiration dates for the two U.S. patents
for
which Alpha Innotech is an assignee.

Customers, page 31
43. To the extent that any of Alpha Innotech`s customers account
for
10% or more of its revenues, please specifically identify such.
If
you have agreements with these parties, please describe the
material
terms of the agreements.

Distribution, page 31

44. If you are substantially dependent on any distribution
agreements, please revise to describe the material terms of the
agreements.

Financial Information, page 32

45. Please revise the document to include the following
information
for Alpha: selected financial data, pro forma selected financial
data, supplementary financial information, and per share data of
the
registrant and company being acquired.  Refer to Items 3(d)-(f)
and
17(b)(3)-(4) of the Rules for Form S-4.

Management`s Discussion and Analysis of Financial Condition for
the
Fiscal Year Ended December 31, 2004 and Quarter Ended March 31,
2005,
page 32

Liquidity and Capital Resources, page 36

46. Please expand your discussion to address material changes in
the
underlying drivers including the specific inflows and outflows
generated, rather than merely describing items identified on the
face
of the statement of cash flows.  Consistent with Section IV of
Financial Reporting Release 72, your discussion should focus on
the
primary drivers of and other material factors necessary to an
understanding of the company`s cash flows and the indicative value
of
historical cash flows.  Where there has been material variability
in
historical cash flows, focus on the underlying reasons for the
changes, as well as on the reasonably likely impact on future cash
flows and cash management decisions.

47. Please revise this discussion to reference the additional $1.5
million of financing in the section titled "Alpha Innotech Loan
from
Alexandria" at the bottom of page 19.

Unaudited Pro Forma Financial Statements

Notes to Unaudited Pro Forma Consolidated Financial Information,
page
44

48. Please revise these notes to include detailed discussion of
the
accounting treatment applied as a result of this merger.  Include
a
detailed discussion of the shares issued and the shares
outstanding
prior to the merger.  Include a note that reconciles the shares
used
in calculating the per share information.  Also revise these
discussions to include specific references within the statements
that
specifically detail the reason and impact of each adjustment on
those
statements.

49. Please explain to us the appropriateness of backing out all of
the operations of Xtrana on a pro forma basis in the pro forma
statements of operations.

Exchange of Stock Certificates, page 50

50. In the table titled "Reverse Stock Split" on the top of page
51
you include line items that disclose the number of shares that
will
be issued as a result of the merger transaction.  Please include a
reconciliation of how you arrived at these amounts from the number
of
shares and warrants disclosed in the historical financial
statements
of Alpha included as Exhibit C.


Proposal No. 3: Amend the Company`s Certificate of Incorporation
to
Provide for a Reverse Stock Split, page 48

51. Please disclose how many shares are currently authorized and
how
many will be outstanding after the merger.

Incorporation by Reference, page 56

52. Please revise to include the file number of the periodic
reports
incorporated by reference.


Proxy Card

53. We note that your proxy card grants discretionary authority to
vote on other matters as may properly come before the meeting.
Please make this discretionary authority a separate proposal that
shareholders can vote on.  Also, please note that such
discretionary
authority cannot be used to adjourn the meeting for the purpose of
soliciting additional votes.  If you anticipate that you may
adjourn
the meeting to solicit additional votes, revise to include a
separate
vote on this matter.

Financial Statements - Alpha Innotech Corporation - December 31,
2004

Report of Independent Auditors, page C-10

54. Please include a completed and electronically signed
accountant`s
report.  See Rule 3-02 of Regulation S-T, which discusses
signatures
in electronic submissions.  Retain the manually signed documents
for
a period of five years.

Consolidated Balance Sheets, page C-11

55. Please disclose the aggregate liquidation preference of your
"Redeemable Convertible Preferred stock" on the face of the
balance
sheet.  Refer to paragraph 6 of SFAS 129.

Notes to Consolidated Financial Statements

2.  Summary of Significant Accounting Policies, page C-16

Segment Reporting

56. Please revise your disclosure to address the requirements to
include the enterprise wide disclosures required by paragraphs 36-
39
of SFAS 131.  Specifically address the need to disclose product or
similar product revenues.

Revenue Recognition, page C-17

57. Please revise your discussion of your policy related to
software
sales to address how the criteria referenced here apply to the
specific facts and circumstances related to your sales to which
you
apply this policy.


4.  Debt, page C-21

BFI Business Finance Line of Credit, page C-21

58. Please revise your discussion of this line of credit to
disclose
the amount available at year-end under the terms of the line
considering that it has a limit of "up to 80% of the Company`s
accounts receivable."

7.  Redeemable Convertible Preferred Stock

Conversion, page C-25

59. Please explain to us the facts and circumstances that resulted
in
the apparent adjustment to the conversion rate for the Series A
shares.  Include a discussion of the accounting consequences of
this
adjustment including references to the specific paragraphs within
the
accounting literature upon which you relied to determine this
treatment.

Warrants for Common Stock, page C-26

60. We note your disclosure in the first paragraph of this section
that warrants were issued to your shareholders to purchase an
aggregate of 1 million shares of common stock "as additional
consideration for the shareholders` investment in the Company".
Please explain your statement that the fair value of $240,000 was
a
discount to notes payable and should be recorded as interest
expense
for the year ended December 31, 2004.  We do not understand the
correlation to notes payable here.

61. Please explain to us how you determined the fair value
assigned
to the warrants that were issued upon the forfeiture of salaries
discussed in the second paragraph of this section.  Include
specifically how the fair value of the warrants issued related to
the
$363,000.

11.  Prior Period Adjustment, page C-29

62. Please revise this note to include a better discussion of the
nature of the revenue that prematurely recognized and what caused
the
error.  Also include a discussion of any impact that the
recognition
of this previously unrecorded deferred revenue had on the current
periods.

Form 10-K for the year ended December 31, 2004

63. Please file your consulting agreement with James Chamberlain
as
an exhibit.


*	*	*

	As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
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 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 filings;
* 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.

	You may contact James Peklenk at (202) 551-3661 or Jim
Atkinson
at (202) 551-3674 if you have questions regarding comments on the
financial statements and related matters.  Please contact Albert
Lee
at (202) 551-3654 or me at (202) 551-3715 with any other
questions.

								Sincerely,



								Jeffrey Riedler
								Assistant Director





??

??

??

??

James H. Chamberlain
Xtrana, Inc.
Page 11