K E N N E T H I. D E N O S, P. C.
11585 SOUTH STATE, SUITE 102
DRAPER, UTAH 84020
(801)816-2511
FAX:(801)816-2599
KDENOS@DENOSLAW.COM
September 26, 2005
VIA FEDERAL EXPRESS
Mr. Jay Ingram
Mr. John Reynolds
U.S. SECURITIES AND EXCHANGE COMMISSION
Division of Corporate Finance
Office of Emerging Growth Companies
450 Fifth Street, N.W., Mail Stop 0511
Washington, D.C. 20549
Telephone (202) 942-2791
Facsimile (202) 942-9516
RE: CANCER THERAPEUTICS, INC.
REGISTRATION STATEMENT ON FORM SB-2
FILE NO. 333-119915
AMENDMENT FILED: SEPTEMBER 26, 2005
Dear Messrs. Ingram and Reynolds:
This firm serves as counsel to Cancer Therapeutics, Inc. in connection with
its submission of a registration statement with the Securities and Exchange
Commission on Form SB-2. We have updated the financial statements in accordance
with your letter dated August 5, 2005. We have attached two redlined copies and
one clean copy of our amended registration statement on Form SB-2 and have
marked it Amendment 7 for your timely review. We note to you that references to
page numbers in the registration statement will be with respect to the redlined
copies.
We hope that our responses to your comment has been both timely and
succinct. If you require any further information, please contact me at the
number above via telephone or fax, or by e-mail at kdenos@denoslaw.com.
KENNETH I. DENOS P.C.
/S/ Kenneth I. Denos
------------------------
Kenneth I. Denos
cc: Robert Oldham, M.D.
Michael Low
Chene Gardner