May 18, 2005 Thomas Flinn, Staff Accountant Division of Corporation Finance United States Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Re: Orthodontix, Inc. (the "Company") Form 8-K filed May 13, 2005 File No. 0-27836 Dear Mr. Flinn: In response to your letter of May 17, 2005, the Company has today filed an amended Form 8-K to provide additional disclosure. This letter will confirm that the Company acknowledges its responsibility for the adequacy and accuracy of the disclosure in Company filings. The Company also acknowledges that staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing. The Company further acknowledges that 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. Very truly yours, Alan Jay Weisberg Acting Chief Financial Officer (Principal Financial and Accounting Officer)