Cover
Letter
[LOGO]
December
13, 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 November 7, 2006 comment to the Company. The paragraph
numbers in this letter correspond to those in your comment letter.
Registration
Statement on Form SB-2
Results
of Operations, page 23
1.
The
Company has made the appropriate revisions.
Proposed
Milestones to Implement Business Operations, page 25
2.
The
Company has made the appropriate revisions.
Financial
Statements
3.
The
Company has provided updated financial statements.
4.
The
Company has provided updated financial statements.
5.
The
Company has provided an updated consent from its accountants.
Signature
Page
6.
The
Company has provided the revision.
Ms
Sara D. Kalin
December
13, 2006
Page 2
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.
David
Wagner