[LOGO]
October
12, 2006
Ms
Sara
D. Kalin
Branch
Chief-Legal
U.S.
Securities and
Exchange
Commission
100
F
Street, N. E.
Washington,
D.C. 20549
Re:
Art
Design, Inc. (the Company)
Form SB-2 Registration Statement
File Number: 333-136012
Dear
Ms.
Kalin;
This
is
in response to your September 25, 2006 comment to the Company. The paragraph
numbers in this letter correspond to those in your comment letter.
Registration
Statement on Form SB-2
1.
Your
comment has been noted. This is to confirm that the only changes made were
in
response to your comments or were highlighted in redlines available for your
review. Please note that we will provide you with an electronic version which
shows all redlined changes from the original Form SB-2 filing.
3.
The
Company has provided evidence of the required changes.
4.
The
Company has made the required clarification.
5.
The
Company has added the required additional risk factor.
6.
The
Company has provided the additional disclosures.
7.
The
Company has made the additional disclosures.
8.
The
Company has made the required clarification.
9.
The
Company has deleted provision.
10.
The
Company has provided evidence of the required changes.
11.
The
Company has made the requested change.
12.
The
Company has provided additional disclosure.
13.
The
Company has made the appropriate revisions. Please note that we have added
comparative financial information for June, 2005.
14.
The
Company has provided additional information to reconcile the
disclosure.
15.
Your
comment has been noted. The Company has provided additional
clarification.
16.
The
Company has made the appropriate revisions.
17.
The
Company has made the appropriate revisions.
18.
The
Company has provided the revision.
The
Company has noted the comments by the Staff in the closing section. If you
have
any additional questions, do not hesitate to contact the undersigned at
(303)793-0304. For accounting comments, please contact Mr. Ronald Chadwick
at
(303) 306-1967.
DAVID
WAGNER & ASSOCIATES, P.C.
/s/
David Wagner
David
Wagner