Mail Stop 6010


							July 21, 2005

Via Facsimile to (604) 301-9546 and U.S. Mail

Mr. Patrick McGowan
Chief Financial Officer
MIV Therapeutics, Inc.
1-8765 Ash Street
Vancouver, B.C. Canada V6P 6T3


	Re:	MIV Therapeutics, Inc.
		Form 10-KSB/A for the fiscal year ended May 31, 2004
		Form 10-QSB for the quarterly period ended February 28,
2005
		File No. 000-30453

Dear Mr. McGowan:

      We have reviewed your response letter dated July 18, 2005
and
have the following additional comments.  We have limited our
review of
your filing to those issues we have addressed in our comments.
Where
indicated, we think you should revise your documents 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 information so we
may
better understand your disclosure.  After reviewing this
information,
we may 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 comment or on any other aspects
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.


Form 10-KSB/A for the fiscal year ended May 31, 2004

Report of Independent Registered Public Accounting Firm, Page F-2

1. We note that in response to our prior comment 1 in our letter
dated
July 5, 2005 you amended your May 31, 2004 Form 10-KSB to include
the
audit report of your prior auditors.  Please revise your Form 10-
KSB
to address the following:

* The audit report should be filed with your financial statements
in
Item 7 of your Form 10-KSB.
* The audit report should be dated to comply with AU Section 530:
Dating of the Independent Auditor`s Report and Rule 2-02(a) of
Regulation S-X.
* The audit report should reference "the standards of the Public
Company Accounting Oversight Board (United States)" rather than
GAAS.
This revision is required to comply with PCAOB Auditing Standard
No. 1
since the audit report was reissued after May 24, 2004.

Form 10-QSB for the quarterly period ended February 28, 2005

Notes 11 - Acquisition of Sagax, Inc., page F-14

2. We note your response to our prior comment 2 in our letter
dated
July 5, 2005.  Please clarify why you believe no historical or pro
forma financial statements are required in connection with the
Sagax,
Inc. acquisition.  We assume you do not consider it to be the
acquisition of a business.  If true, using the guidance set forth
in
EITF 98-3 and Rule 11-01(d) of Regulation S-X, please provide us
with
a detailed analysis supporting your conclusion that Sagax, Inc
does
not meet the definition of a business.  Also, please provide us
with
your purchase price allocation.  If not the case, tell us more
about
the reasons for your response to our prior comment.  Amend your
Form
8-Ks to include any required historical and pro forma financial
statements for the acquisition.  Refer to Item 310(c) and Item
310(d)
of Regulation S-B.

      As appropriate, please amend your May 31, 2004 Form 10-KSB
and
respond to these comments within 10 business days or tell us when
you
will provide us with a response.  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 file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your amendment and responses
to
our comments.

	You may contact Eric Atallah, Staff Accountant at (202) 551-
3663
or me at (202) 551-3603 regarding comments on the financial
statements
and related matters.  In this regard, do not hesitate to contact
Angela Crane, Branch Chief, at (202) 551-3554.


      								  Sincerely,


								  Jay Webb
								  Reviewing Accountant
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Mr. Patrick McGowan
MIV Therapeutics, Inc.
July 21, 2005
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