CORRESP 1 filename1.txt HAROLD W. PAUL, LLC ATTORNEY AT LAW PO Box 33812 Santa Fe, NM 87594 (505) 983-2794 Fax (866) 644-7615 June 3, 2009 Mr. Howard Efron Securities and Exchange Commission Mail Stop 4561 100 F Street, NE Washington, DC 20549 Re: Ozone Man, Inc. Form 10-K For the year ended December 31, 2008 File No. 0-09908 Dear Mr. Efron: We represent TOMI Environmental Solutions, Inc., formerly The Ozone Man, Inc. Our client has forwarded to us your letter dated May 14, 2009 and authorized us to reply. Supplementally, we advise as follows: Form 10-K for the year Ended December 31, 2008 ---------------------------------------------- Financial Statements -------------------- Note 4 - Intangible Assets, page F-12 ------------------------------------- 1. Management's basis for determining the deferral of amortization on the Company's intangible assets is that the benefit derived from such intangible assets will not occur until such time as when the Company commences principal operations. The Company will amortize its intangibles over their estimated useful lives, based on an analysis of pertinent factors, including the expected use of the asset by the entity (SFAS 142 11a). Note 13 - Forgiveness of Debt, page F-17 ---------------------------------------- 2. As a matter of clarification, $25,000 was forgiven. The obligation of the Company for past due legal services was $50,000. $25,000 was forgiven and the balance was represented by the convertible promissory note. HAROLD W. PAUL, LLC Mr. Howard Efron Securities and Exchange Commission June 3, 2009 Page Two Exhibits 31.1 and 31.2 ---------------------- 3. The staff's comment regarding certain modifications to the certifications is noted and we represent that all future filings commencing with the Company's 10-Q for the period ending June 30, 2009 will conform to the exact form set forth in Item 601(b)(31) of Regulation S-K. The Company acknowledges that: . the company is responsible for the adequacy and accuracy of the disclosure in the filing; . staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and . 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. Please do not hesitate to contact the undersigned if you have any further comments or questions. Sincerely, /s/ HAROLD W. PAUL, LLC /sl HAROLD W. PAUL, LLC cc: Halden Shane TOMI Environmental Solutions, Inc.