OCCULOGIX, INC.
                      2600 Skymark Drive, Unit 9, Suite 201
                              Mississauga, Ontario
                                     L4N 5B2
                                     Canada

                                                                December 6, 2004


Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C.  20549

RE:   OCCULOGIX, INC.
      REGISTRATION STATEMENT ON FORM S-1
      REGISTRATION NO. 333-118204


Ladies and Gentlemen:

          OccuLogix, Inc. (the "Company") hereby requests that the effective
date of the above-referenced Registration Statement be accelerated so that it
may become effective at 3 p.m. on December 7, 2004, or as soon thereafter as
practicable.

          We understand that the Staff will consider this request as
confirmation by the Company of its awareness of its responsibilities under the
federal securities laws as they relate to the securities of the Company covered
by the Registration Statement.


                                     Sincerely,

                                     OccuLogix, Inc.


                                     By: /s/ William G. Dumencu
                                         --------------------------------------
                                     Name: William G. Dumencu
                                     Title: Chief Financial Officer