[INOVIO BIOMEDICAL CORPORATION LOGO]
VIA EDGAR AND FACSIMILE (202) 942-9585
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Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20659
Attn: Mary Beth Breslin
April 12, 2005
RE: Inovio Biomedical Corporation Registration Statement on Form S-3 File
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No. 333-123619(filed as Genetronics Biomedical Corporation on March 28, 2005)
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Dear Ms. Breslin:
Pursuant to Rule 461 of the Securities Act of 1933, as amended, Inovio
Biomedical Corporation, a Delaware corporation (the "Company"), hereby requests
that the Securities and Exchange Commission ("SEC") take appropriate action to
cause the above-referenced Registration Statement to become effective at 5:00 PM
Eastern Standard Time on April 13, 2005 or as soon thereafter as possible.
Please note that there are no underwriters of the proposed secondary offering of
the shares of the Company's common stock being registered pursuant to the
Registration Statement. Further, the Company acknowledges that:
o Should the SEC or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the SEC from taking
any action with respect to the filing;
o The action of the SEC or the staff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve the
Company from its full responsibility for the adequacy and accuracy of
the disclosure in the filing; and
o The Company may not assert this action as defense in any proceeding
initiated by the SEC or any person under the federal securities laws of
the United States.
Should you have any questions or require any additional information with respect
to this filing, please contact Anh Tran or Thomas Poletti at (310) 552-5000 or
by facsimile at (310) 552-5001. Thank you for your assistance and cooperation.
Yours very truly,
Inovio Biomedical Corporation
/s/ Peter Kies
Peter Kies
Chief Financial Officer
cc: Thomas J. Poletti, Esq.