Mail Stop 3-09

							February 10, 2005


Daniel C. Montano
Chief Executive Officer
CardioVascular BioTherapeutics, Inc.
1700 West Horizon Ridge Parkway, Suite 100
Henderson, Nevada 89012

Re:	CardioVascular BioTherapeutics, Inc.
	Registration Statement on Form S-1, Amendment 4
	File Number 333-119199

Dear Mr. Montano:

	We have reviewed your filing and have the following comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

FORM S-1

If you are not an institutional investor, you may purchase our
securities . . . , page 18

1. We note this risk factor lists the states your stock will be
offered in as "[New York, Florida and ________]."  Similar
disclosure
appears on page 66.  Please complete this list of states prior to
effectiveness.

Executive Compensation, page 52

2. Please revise to provide updated information regarding
executive
compensation, option/warrant grants, and option/SARs exercises for
the year ended December 31, 2004.  Please note, you should
continue
to include the information for the year ended December 31, 2003.

*	*	*

	As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

	We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

	You may contact Joel Parker at (202) 824-5487 or Mary Mast at
(202) 942-1858 if you have questions regarding comments on the
financial statements and related matters.  Please contact Greg
Belliston at (202) 824-5219, Suzanne Hayes at (202) 942-1789, or
me
at (202) 942-1840 with any other questions.

							Sincerely,



							Jeffrey Riedler
							Assistant Director

cc:	David R. Decker, Esq.
	Ronald Warner, Esq.
	Kristine Lefebvre, Esq.
	Lord Bissell & Brook, LLP
	300 South Grand Avenue
	Los Angeles, California 90071
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Daniel C. Montano
CardioVascular BioTherapeutics, Inc.
February 10, 2005
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