Mail Stop 6010


August 9, 2005

Mr. James W. Albrecht, Jr.
Chief Financial Officer
Introgen Therapeutics, Inc.
301 Congress Avenue, Suite 1850
Austin, TX 78701

      Re:	Introgen Therapeutics, Inc.
		Form 10-K for the fiscal year ended December 31, 2004
		Form 10-Q for the quarter ended March 31, 2005
	File No. 000-21291

Dear Mr. Albrecht:

      We have limited our review of your filing to the issue we
have
addressed in our comment.  Where indicated, we think you should
revise your document in response to this comment.  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.

	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
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 30

1. We acknowledge your table included in the section entitled
"Product Development Programs" on page 9. However, we believe that
your disclosures about historical research and development
expenses
and estimated future expenses related to your major research and
development projects could be enhanced for investors.  Please
refer
to the Division of Corporation Finance "Current Issues and
Rulemaking
Projects Quarterly Update" under section VIII - Industry Specific
Issues - Accounting and Disclosure by Companies Engaged in
Research
and Development Activities.  You can find it at the following
website
address:
http://www.sec.gov/divisions/corpfin/cfcrq032001.htm#secviii.

Please disclose the following information for each of your major
research and development projects:

a. The costs incurred during each period presented and to date on
the
project;
b. The nature, timing and estimated costs of the efforts necessary
to
complete the project;
c. The anticipated completion date;
d. The risks and uncertainties associated with completing
development
on schedule and the consequences to your operations, financial
position and liquidity if the project is not completed timely;
and,
finally
e. The period in which material net cash inflows from your
significant projects are expected to commence.

Regarding a., if you do not maintain research and development
costs
by project, please disclose why management does not maintain and
evaluate research and development costs by project.  Include other
quantitative or qualitative analyses that indicate the amount of
the
company`s resources being used on these projects.

Regarding b. and c., please disclose the amount or range of
estimated
costs and timing to complete the phase in process and each future
phase. To the extent that information is not estimable, please
disclose the facts and circumstances indicating the uncertainties
that preclude you from making a reasonable estimate.


*    *    *    *
      Please amend your filing and subsequent Form 10-Q for the
quarter ended March 31, 2005 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 comment and provides any requested information.  Detailed
cover letters greatly facilitate our review.  Please file your
letter
on EDGAR under the form type label CORRSEP.  Please understand
that
we may have additional comments after reviewing your amendment.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that they
have
provided all information required under the Securities Exchange
Act
of 1934 and that they have provided all information investors
require
for an informed investment 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 your letter, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure 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 staff comments 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 our review of your filing
or
in response to our comments on your filing.

      You may contact Amy Bruckner, Staff Accountant, at (202)
551-
3657 or Joel Parker, Accounting Branch Chief, at (202) 551-3651 if
you have questions regarding comments on the financial statements
and
related matters.  Please contact me at (202) 551-3679 with any
other
questions.

      Sincerely,


							Jim B. Rosenberg
							Senior Assistant Chief
Accountant
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James W. Albrecht, Jr.
Introgen Therapeutics, Inc.
August 9, 2005
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