Via Facsimile and U.S. Mail
Mail Stop 6010


										August 8, 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
	Amendment No. 2
	Filed July 29, 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

Background of the Merger, page 17
1. We note your response to comment 5 and your statement that the
consideration was based upon the relative values attributed by the
parties.  Please explain how each party`s value was determined.
For
example, how did you value your status as a public company?  What
was
the value you attributed to your company and what was the value
you
attributed to Alpha Innotech?
2. As currently written, it appears that the Board of Directors
approved the merger agreement with Alpha Innotech on December 2,
2004
and that the Board also approved the formal engagement of The
Mentor
Group on the same date.  If this chronology is accurate, please
revise to clarify The Mentor Group`s basis for indicating that
there
was a high likelihood that the transaction was fair to the
stockholders from a financial transaction point of view.  If the
chronology is not accurate, disclose the date that the Board
approved
the engagement of The Mentor Group.
3. Also, clarify how The Mentor Group`s belief that there was a
high
likelihood that the transaction would be deemed fair was
communicated
to the Board.
4. We note your statement that in approving the transaction the
Board
relied on discussions with its financial advisors.  Please revise
to
include descriptions of all of the Mentor Group`s discussions with
the Board.
5. It appears from your disclosure that The Mentor Group may have
begun its due diligence before they were formally engaged.  If
this
is accurate, then disclose the date they began their due diligence
and clarify what analyses had been completed when the Board voted
to
approve the merger and disclose whether the Board was aware of the
outcome of these analyses.

Opinion of Financial Advisor to the Board of Directors, page 29
6. We note your response to comment 11.  You continue to refer to
the
conditions, scope limitations and understandings set forth in the
engagement letter.  If these are the same conditions, limitations
and
understandings set forth in the discussion, please revise to
indicate
that they are the same ones identified in the preceding
paragraphs.
Otherwise, revise to identify the conditions, limitations and
understandings that are set forth in the engagement letter.

Alpha Innotech Business and Financial Information, page 39
7. Please revise to indicate when the latest to expire patent
under
the DigiOpt agreement is scheduled to expire.

Risk Factors, page 42

Alpha Innotech has a history of operating losses and may incur
future
losses, page 42
8. We note your response to comment 17 and reissue the comment in
part.  Please revise to disclose Alpha Innotech`s accumulated
deficit.

Financial Statements - Alpha Innotech Corporation - December 31,
2004

Notes to Consolidated Financial Statements, page C-16

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

Revenue Recognition, page C-17
9. We have reviewed your revised disclosure in response our
comment
23 of our July 21, 2005 letter.  Please clarify in your disclosure
what you mean by "primarily" and "generally" in the first sentence
of
the first paragraph and by "generally" in the fourth paragraph of
the
second paragraph. To extent that you have other sources of revenue
and/or other methods of revenue recognition, please describe and
explain them in your disclosure.

7.  Redeemable Convertible Preferred Stock, page C-25
10. We have reviewed your July 28, 2005 response to comment 24.
Please provide further analysis of how you concluded that the
adjustment to the Series A Preferred did not require you to record
a
contingent beneficial conversion amount. Specifically address
Issue 7
of EITF 00-27 and provide us your calculations.

*	*	*

      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.

	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.
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