9701 Wilshire Blvd., Suite 1100, Beverly Hills, CA 90212
Phone (310) 274-2036
Fax (310) 271-2632
Email info@CardoMedical.com

July 31, 2009

In connection with its response to the United States Securities and Exchange Commission's comment letter, dated June 26, 2009, Cardo Medical, Inc. (the "Company") acknowledges the following:

• 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 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.

CARDO MEDICAL, INC.

By: /s/ Derrick Romine
Derrick Romine
Chief Financial Officer