Feder, Kaszovitz, Isaacson, Weber, Skala, Bass & Rhine, LLP

International Plaza

750 Lexington Avenue

New York, NY 10022-1200

Tel. (212) 888-8200

Fax. (212) 888-7776

February 13, 2008

U.S. Securities & Exchange Commission

Division of Corporate Finance

M.S. 6010

Washington, DC 20549

Attn:

Russell Mancuso, Branch Chief

RE:

Forticell BioScience, Inc. (formerly known as Ortec International, Inc.)

Amendment No. 6 to Form SB-2

Filed February 12, 2008

File No. 333-146142

Gentlepersons:

Please provide us your analysis that supports your conclusions in your response to prior comment 4 as it applies to each selling shareholder in the table beginning on page 38. We note, for example, that given the number of your shares registered on Form S-2 file no. 333-124773 for sale by SDS Capital, the analysis required by prior comment 4 would seem to indicate that no additional shares would be included for that selling shareholder in the current registration statement; however, your response to prior comment 4 and the disclosure in your prospectus appears to indicate that you are registering additional shares for sale by SDS Capital.

Response:

We have recalculated the number of shares that we can register for each of the six Selling Stockholders referred to in our February 12, 2008 letter. In our analysis we have used as the maximum number of registrable shares any Selling Stockholder (or group) could register in this registration statement and in prior registration statements is 10% of Forticell’s common shares outstanding held by non-affiliates (1,131,210 shares).

No reduction has to be made in the number of shares registered for any other Selling Stockholder because of shares registered for such Selling Stockholder in previous registration statement.

U.S. Securities & Exchange Commission

February 13, 2008

Page 2

Jason Adelman

Total permitted (one half of 1,131,210 shares because he and Michael Liss constitute a group)		565,605
Less - registered in previous registration statements for Jason Adelman for CGA Resource LLC (an affiliate of Mr. Adelman)	343,085 74,208
	417,293	417,293
Additional shares that may be registered		148,312
Plus shares previously registered and continued to be registered as a result of this registration statement being an amendment to prior registration statements - common shares		269,353
Total to be listed in this prospectus		417,665

Matthew Balk

Total permitted to be registered		1,131,210
Less - registered in previous registration statements		62,566
Additional shares that may be registered		1,068,644
Plus shares previously registered and continued to be registered as a result of this registration statement being an amendment to prior registration statements - shares underlying Series B-1, EPA, F and FPA warrants		45,772
Total to be listed in this prospectus		1,114,416

U.S. Securities & Exchange Commission

February 13, 2008

Page 3

Michael Liss

Total permitted to be registered (one half of 1,131,210 because he and Jason Adelman are a group)		565,605
Less - registered in previous registration statements		31,055
Additional shares that may be registered		534,550
Plus shares previously registered and continued to be registered as a result of this registration statement being an amendment to prior registration statements - shares underlying Series C and F warrants		5,707
Total to be listed in this prospectus		540,257

SDS Capital Group SPC, Ltd.

Total permitted to be registered		1,131,210
Less - registered in previous registration statements		1,022,742
Additional shares that may be registered		108,468
Plus shares previously registered and continued to be registered as a result of this registration statement being an amendment to prior registration statements - shares underlying Series E and F warrants		342,507
Total to be listed in this prospectus		450,975

U.S. Securities & Exchange Commission

February 13, 2008

Page 4

SXJE LLC

Total permitted to be registered		1,131,210
Less - registered in previous registration statements		75,439
Additional shares that may be registered		1,055,771
Plus shares previously registered and continued to be registered as a result of this registration statement being an amendment to prior registration statements - shares underlying Series F warrants		10,934
Total to be listed in this prospectus		1,066,705

The four Visium funds (as one group)

Total permitted to be registered		1,131,210
Less - registered in previous registration statements		1,120,002
Additional shares that may be registered		11,208
Plus shares previously registered and continued to be registered as a result of this registration statement being an amendment to prior registration statements - common shares		560,002
Total to be listed in this prospectus		571,210

Amendment no. 7 to Forticell’s registration statement makes the changes in the number of registered shares as set forth above.

U.S. Securities & Exchange Commission

February 13, 2008

Page 5

2.	Please revise your document to reflect the revisions mentioned in your February 12, 2008 fax to us.

Response:

Amendment no. 7 to the registration statement reflects the changes mentioned in our February 12, 2008 fax to you.

Yours very truly,

/s/ Gabriel Kaszovitz

Gabriel Kaszovitz

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