[LOGO]
October
24, 2006
Ms
Sara
D. Kalin
Branch
Chief-Legal
U.S.
Securities and
Exchange
Commission
100
F
Street, N. E.
Washington,
D.C. 20549
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Re: |
Art Design, Inc. (the
Company)
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Form
SB-2 Registration Statement
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Dear
Ms.
Kalin;
This
is
in response to your October 19, 2006 comment to the Company. The paragraph
numbers in this letter correspond to those in your comment letter.
Registration
Statement on Form SB-2
General
1.
The
Company has filed the revised escrow agreement.
We
may
need to raise additional funds…page 8
2.
The
Company has provided the additional disclosures.
Because
our current officers and directors… a conflict of interest, page
8
3.
The
Company has made the additional disclosures.
4.
The
Company has made the required clarification.
Results
of Operations, page 23
5.
The Company has made the appropriate
revisions.
Liquidity
and Capital Resources,
page 23
6.
The Company has deleted the relevant
language.
Proposed
Milestones to Implement
Business Operations, page 24
7.
The Company has made the appropriate
revisions.
Annex
A
8.
The Company has moved Annex
A.
Signature
Page
9.
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.
David
Wagner