Via Facsimile and U.S. Mail
Mail Stop 6010


August 31, 2005


Ronald G. Hosking
Vice President and CFO
IMI International Medical Innovations Inc.
4211 Younge Street, Suite 615
Toronto, Ontario M2P 2A9
Canada

Re:	IMI International Medical Innovations Inc.
	          Form 6-K/A
	           Filed October 21, 2004
                     File No.  001-31360

Dear Mr. Hosking:

      We have limited our review of your filing to those issues we
have addressed in our comment.  In our comment, we ask you to
provide
us with information so we may better understand your disclosure.

	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.

`` General
1. We note from section 17.3(e) of the License, Development and
Supply Agreement with McNeil PDI Inc., filed October 21, 2004 as
an
exhibit to your Form 6-K/A, that the agreement contemplates
licensing
or other operations in Iran and Syria.  In light of the fact that
these countries are identified as state sponsors of terrorism by
the
U.S. State Department, and are subject to economic sanctions
administered by the Treasury Department`s Office of Foreign Assets
Control, please describe for us all existing and anticipated
operations in these countries.  Please also discuss the
materiality
of your operations and anticipated operations in Iran and Syria,
and
your view as to whether those operations and/or anticipated
operations, individually or in the aggregate, constitute a
material
investment risk for your security holders.  In preparing your
response please consider that evaluations of materiality should
not
be based solely on quantitative factors, but should include
consideration of all factors that a reasonable investor would deem
important in making an investment decision, including the
potential
impact of corporate activities upon a company`s reputation and
share
value.

*    *    *    *

      Please provide us the information requested within 10
business
days of the date of this letter or tell us when you will provide a
response prior to the expiration of the 10-day period. Please
furnish
a letter with your responses that keys your response to our
comment.
Detailed letters greatly facilitate our review.  You should file
the
letter on EDGAR under the form type label CORRESP.  Please
understand
that we may have additional comments after reviewing your response
to
our comment.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes 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 writing, 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 Sasha Parikh, Staff Accountant, at (202)
551-
3627 or Joel Parker, Accounting Branch Chief, at (202) 551-3651 if
you have questions regarding the comment. In this regard, do not
hesitate to contact me, at (202) 551-3679.

							Sincerely,


							Jim B. Rosenberg
							Senior Assistant Chief
Accountant
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Ronald G. Hosking
IMI International Medical Innovations Inc.
August 31, 2005
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