March 3, 2006


Mail Stop 3628

Via Facsimile and U.S. mail

Mr.  Nick DeMare
Chief Executive Officer
Medina International Corp.
1305-1090 West Georgia Street
Vancouver, British Columbia
V6E 3V7 Canada


Re:	Medina International Corp.
	Schedule 14F-1
	Filed February 17, 2006

	File No. 005-81615

Dear Mr. De Mare:

      We have the following comments on the above referenced
filing. 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 me at the telephone number listed
at the end of this letter.

1. Revise to include all information required by Item 7 of
Schedule 14A and Rule 14f-1.  In this regard, provide the information
required by Item 7(h) regarding shareholder communications.

2. In future filings, please note that the Commission`s present
address is:  100 F Street, NE, Washington, DC 20459.

3. It appears that Dr. Kienan and Biotech Knowledge LLC are
required to file a Schedule 13D in respect of the recent transfer
of shares to Dr. Kienan.  Please file this schedule promptly.

Closing Comment

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be certain that they have provided all information investors require.
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 filings;

* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

      Respond to our comments promptly.  Please furnish a response
letter, keying your response to our comment letter.  You should
transmit the letter via EDGAR under the label "CORRESP."  In the
even that you believe that compliance with any of the above

comments is inappropriate; provide a basis for such belief to the
staff in the response letter.  Please contact me at (202) 551-3267
if you have any questions.


							Sincerely,



							Julia E. Griffith
							Special Counsel
							Office of Mergers and
							   Acquisitions