Converted by EDGARwiz

August 1, 2008

Mr. Craig Wilson

Senior Assistant Chief Accountant

US Securities and Exchange Commission

Division of Corporate Finance

One Station Place

100 F. Street, N.E.

Washington, D.C. 20549-4561

RE: Probe Manufacturing, Inc. Form 10-KSB for Fiscal Year Ended December 31, 2007 filed March 28, 2008 (File No. 333-125678).

Dear Mr. Wilson;

Thank you for your letter dated July 21, 2008. We have reviewed your letter and we are taking the following actions as described below:

We have incorporated your final comments into the Company’s amended 2007 10-KSB report that we intend to file.

We have responded to the questions presented by the staff in a writing presented below.

Please feel free to contact me if you have any additional questions that we can answer for you.

Sincerely,

/s/ Reza Zarif

Reza Zarif

Chief Executive Officer

Cc:

Mr. Jeffrey Conrad, Esq.

The Tower, 10940 Wilshire Blvd., Suite 600, Los Angeles, CA 90024 Tel (310) 443-4102 Fax (310) 443-4103 Web: www.abviva.com

RESPONSES TO QUESTIONS

Item 9A. Controls and Procedures pg. 50

1. The Commission has pointed out that issuer did not include a “Management’s Report on Internal Control Over Financial Reporting” in its annual 10-KSB for the fiscal year 2007.

Response

The Company has amended its 10-KSB for 2007 filing to include the management’s report on internal control over financial reporting. We did not fail to perform such an analysis but failed to include the report in its filing thus there is no impact to the issuer’s conclusions regarding the effectiveness of our disclosures on controls and procedures covered by the report for the fiscal year 2007.

The following is our amended Item 9A. Controls and Procedures which includes our Management’s Report on Internal Control Over Financial Reporting which will be included in our amended 10-KSB filing for the fiscal year 2007:

Item 9A. Controls and Procedures.

Evaluation of Disclosure Controls and Procedures

As of the end of the period covered by this Annual Report on Form 10-KSB, an evaluation was performed under the supervision and with the participation of our management, including the Chief Executive Officer and Chief Financial Officer, of the effectiveness of the design and operation of our disclosure controls and procedures (as defined in Rules 13a-14 and 15d-14 of the Securities Exchange Act of 1934). Based on that evaluation, our Chief Executive Officer and Chief Financial Officer concluded that our disclosure controls and procedures are effective to ensure that information we are required to disclose in reports that we file or submit under the Securities Exchange Act of 1934 (i) is recorded, processed, summarized and reported within the time periods specified in Securities and Exchange Commission rules and forms, and (ii) is accumulated and communicated to our management, including our Chief Executive Officer and Chief Financial Officer, as appropriate, to allow timely decisions regarding required disclosure. Our disclosure controls and procedures are designed to provide reasonable assurance that such information is accumulated and communicated to our management. Our disclosure controls and procedures include components of our internal control over financial reporting. Management's assessment of the effectiveness of our internal control over financial reporting is expressed at the level of reasonable assurance that the control system, no matter how well designed and operated, can provide only reasonable, but not absolute, assurance that the control system's objectives will be met.

Management’s Report on Internal Control Over Financial Reporting

Management is responsible for establishing and maintaining adequate internal control over financial reporting, as such term is defined in Rule 13a-15(f) under the Securities Exchange Act of 1934, as amended. As of December 31, 2007, under the supervision and with the participation of management, including the Company’s Chief Executive Officer and Chief Financial Officer, an evaluation was conducted of the effectiveness of the Company’s internal control over financial reporting based on the framework in Internal Control — Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Based on that evaluation, management concluded that the Company’s internal control over financial reporting was adequately designed and operating effectively as of December 31, 2007.

Because of its inherent limitations, a system of internal control over financial reporting can provide only reasonable assurance and may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

This Annual Report does not include an attestation report of the Company’s registered public accounting firm regarding internal controls over financial reporting. Management’s report was not subject to attestation by the Company’s registered public accounting firm pursuant to temporary rules of the SEC that permit the Company to provide only Management’s Report in this Annual Report.

Changes in Internal Controls

There was no change in our internal control over financial reporting that occurred during the fourth quarter covered by this Annual Report on Form 10-KSB that materially affected, or is reasonably likely to materially affect, our internal control over financial reporting.

Exhibits 31.1 and 31.2

2. The Commission pointed out that the Certifications filed by the issuer did not included the introductory language of paragraph 4 and the language of 4(b) of Item 601 (b)(31) of Regulation SB.

Response

We have amended our certifications as noted and below are our amended certification of our Chief Executive Officer and Chief Financial Officer:

Exhibit 31.1

CERTIFICATION PURSUANT TO

SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002

I, Reza Zarif, certify that:

1. I have reviewed this report on Form 10-KSB/A of Probe Manufacturing, Inc.;

2. Based on my knowledge, this report does not contain any untrue statement of

a material fact or omit to state a material fact necessary to make the

statements made, in light of the circumstances under which such statements

were made, not misleading with respect to the period covered by this

report;

3. Based on my knowledge, the financial statements, and other financial

information included in this report, fairly present in all material

respects the financial condition, results of operations and cash flows of

the registrant as of, and for, the periods presented in this report;

4. The registrant's other certifying officer(s) and I are responsible for

establishing and maintaining disclosure controls and procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act Rules 13-215 (f) and 15d-15(f)) for the registrant and have:

Designed such disclosure controls and procedures, or caused such

disclosure controls and procedures to be designed under our

supervision, to ensure that material information relating to the

registrant, including its consolidated subsidiaries, is made known to

us by others within those entities, particularly during the period in

which this report is being prepared;

Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

Evaluated the effectiveness of the registrant's disclosure

controls and procedures and presented in this report our conclusions

about the effectiveness of the disclosure controls and procedures, as

of the end of the period covered by this report based on such

evaluation; and

Disclosed in this report any change in the registrant's internal

control over financial reporting that occurred during the registrant's

most recent fiscal quarter (the registrant's fourth fiscal quarter in

the case of an annual report) that has materially affected, or is

reasonably likely to materially affect, the registrant's internal

control over financial reporting; and

5. The registrant's other certifying officer(s) and I have disclosed, based on

our most recent evaluation of internal control over financial reporting, to

the registrant's auditors and the audit committee of the registrant's board

of directors (or persons performing the equivalent functions):

a) all significant deficiencies and material weaknesses in the

design or operation of internal control over financial reporting which

are reasonably likely to adversely affect the registrant's ability to

record, process, summarize and report financial information; and

b) any fraud, whether or not material, that involves management or

other employees who have a significant role in the registrant's

internal control over financial reporting.

DATED this 1^st day of August 2008.

/s/ Reza Zarif

______________________________

Reza Zarif, Chief Executive Officer

Exhibit 31.2

CERTIFICATION PURSUANT TO

SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002

I, John Bennett, certify that: