BiOTECH HOLDINGS LTD.
#160- 3751 Shell Road
Richmond, British Columbia
V6X 2W2
Phone: (604) 295-1119
Toll Free: (888) 216-1111
Fax: (604) 295-1110
30 March, 2006
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.
20549
Attention: Amy C Bruckner, Staff Accountant, Division of Corporation Finance
Dear Ms. Bruckner:
Re: Your review comments - Form 20-F for the fiscal
year ended March 31, 2005
File Number 0-29108
Further to your letter of March 16, 2006 and our conversation of today, I have drafted a response to your queries and have passed it on to our auditors for review. As today is the deadline for filing is today, I am not certain that the review process will be done in time. I therefore request an extension to next Friday April 7.
Thank you for your patience in this matter.
Yours truly,
/s/ LORNE BROWN
LORNE BROWN,
Chief FINANCIAL Officer
Biotech Holdings Ltd.