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ThinkEquity Partners LLC 31 West 52nd Street, 17th Floor New York, N.Y. 10019 October 13, 2005 Securities and Exchange Commission Division of Corporate Finance 100 F. Street, N.E. Washington, D.C. 20549 Re: Electro-Optical Sciences, Inc. (the "Company") Registration ----------------------------------------------------------- Statement on Form S- 1 (Reg. No. 333-125517) -------------------------------------------- Ladies and Gentlemen: In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the "Act"), we hereby join with the Company to request that the effective date for the Registration Statement referred to above be accelerated to 4:00 p.m., (New York time) on October 17, 2005 or as soon as practicable thereafter. In connection with Rule 460 of the Act, please be advised that, during the period from September 27, 2005 to the date of this letter, we have effected the following distribution of copies of the Preliminary Prospectus dated September 27, 2005: Number of prospectuses distributed to institutions 433 Number of prospectuses distributed to individuals 58 Number of prospectuses distributed to underwriters 300 ------------- Total 791 The undersigned has and will, and each participating underwriter and dealer has advised the undersigned that it has and will, comply with the provisions of SEC Release No. 33-4968 of the Act and Rule 15c2-8 of the Securities Exchange Act of 1934, as amended in connection with the above-referenced issue. Very truly yours, THINKEQUITY PARTNERS LLP STANFORD GROUP COMPANY By: THINKEQUITY PARTNERS LLP By: /s/ Ben Davey ----------------------- Name: Ben Davey Title: Managing Director, Head of Equity Syndicate 1