Via Facsimile and U.S. Mail
Mail Stop 6010


January 13, 2006


Mr. Robert C. Low
Vice President, Finance and
Acting Chief Financial Officer
Advancis Pharmaceutical Corporation
20425 Seneca Meadows Parkway
Germantown, MD 20876


Re:	Advancis Pharmaceutical Corporation
	Form 10-Q for the Fiscal Period Ended September 30, 2005
	File No. 000-50414

Dear Mr. Low:

      We have reviewed your December 14, 2005 response to our
November 30, 2005 comment letter and have the following comments.
In
our comments, we have asked 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
filings.
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 10-Q - September 30, 2005

Item 1.  Financial Statements (Unaudited), page 2

9.  Private Placement of Common Stock, page 12

1. We read your response to our prior comment number one.  We are
unable to agree with your assertion that these documents should be
viewed separately.  Please note that DIG Issue K-1 provides
guidance
on when to consider certain documents on a combined basis, but is
not
all inclusive, nor does the failure of one of those criterion
indicate that separate documents be viewed separately.  It appears
that the substance of these separate agreements causes them to be
considered on a combined basis. Please provide us an analysis of
the
criteria of paragraph 16 of EITF 00-19 and whether this combined
instrument meets that criteria and allows the instrument to be
included as permanent equity.

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
letter
that keys your response to our comment and provide the requested
information.  Detailed letters greatly facilitate our review.
Please
file your letter on EDGAR under the form type label CORRESP.

	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
as
we requested previously, 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 Tabatha Akins, Staff Accountant, at (202)
551-
3658 or Jim Atkinson, Accounting Branch Chief, at (202) 551-3674
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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Mr. Robert C. Low
Advancis Pharmaceutical Corporation
January 13, 2006
Page 1