EXHIBIT 99.1

                                 March 20, 2002


Office of the Chief Accountant
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

     RE:      ARTHUR ANDERSEN LLP REPRESENTATIONS

Dear Madam or Sir:

         In connection with Arthur Andersen LLP's audit of the financial
statements of Introgen Therapeutics, Inc. (the "Company") for the six-month
transition period ended December 31, 2001, Arthur Andersen LLP has made the
following representations to the Company:

         1. The audit was subject to Arthur Andersen LLP's quality control
system for the U.S. accounting and auditing practice to provide reasonable
assurance that the engagement was conducted in compliance with professional
standards;

         2. There was appropriate continuity of Arthur Andersen LLP personnel
working on the audit;

         3. Consultation with the national office of Arthur Andersen LLP
regarding the audit was available; and

         4. Personnel at foreign affiliates of Arthur Andersen LLP were
available to conduct the relevant portions of the audit, where applicable.

         Please contact me if you have any questions regarding the foregoing.

                                      Very truly yours,

                                      /s/ James W. Albrecht, Jr.

                                      James W. Albrecht, Jr.
                                      Chief Financial Officer



Copy to: David Winn, Arthur Andersen LLP