NeoGenomics, Inc.

12701 Commonwealth Drive

Fort Myers, FL 33913

July 12, 2007

Susann Reilly, Attorney

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E., Mail Stop 3561

Washington, DC 20549

Re: NeoGenomics, Inc.

      Amendment No. 1 to Form SB-2 Filed July 6, 2007

Dear Ms. Reilly:

This letter is in response to your correspondence dated July 11, 2007.  We have had our auditors update their report to add the city and state of issuance and an indication that the report had been signed as referred to in Section 210.2-02(a) of Regulation S-X and Section 232.302 of Regulation S-T.

At the present time we are filing Amendment No. 1 to Form SB-2 Filed July 6, 2007.

Warm Regards,

/s/ Robert Gasparini

Robert Gasparini

President and Prinicpal Executive Officer