Mail Stop 0308

							March 30, 2005



Richard Lee
Viropro, Inc.
4480 Cote de Liesse Nuite 355
Montreal Quebec
CANADA  H4N2R1


	RE:	Viropro, Inc.
		Item 4.01 Form 8-K filed January 26, 2005
            	File No. 333-6718


Dear Mr. Lee:

          We have reviewed the above referenced filing and have
the
following comments.  We welcome any questions you may have about
our
comments.  Feel free to contact us at the telephone numbers listed
at
the end of this letter.

1. The letter from your former accountants included as Exhibit 16
is
not the letter required by Item 304(a)(3) of Regulation S-B.
Please
amend your filing to include a letter from your former accountants
stating whether or not they agree with the disclosures in the
filing.

2. Please note that our records show that your file number is 333-
6718.  Please use this number on the cover of your amendment or
advise.

3. Please note that your filing was not timely since it was due
within four business days from the date of resignation.  Your
document header filed on the EDGAR system reflected a date of
December 1, 2004 as the period date; however, the cover of your
document shows a date of January 14, 2005.  You may want to
correct
the EDGAR header in your amendment.





Richard Lee
Viropro, Inc.
March 30, 2005
Page 2



      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.


	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosures 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 this action as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.


	The amendment requested above should be filed within five
business days from the date of this letter or we should be advised
by
that date when it will be filed.  The amendment should include an
appropriate from your former accountants indicating that they have
read the Form 8-K/A.  Please file your response to these comments
as
an EDGAR correspondence file at the same time as you file the Form
8-
K/A.  Any questions regarding the above should be directed to me
at
(202) 942-1809, or in my absence, to Robert Benton at (202) 942-
1811.

							Sincerely,



							Robert Burnett
						            Staff Accountant


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