[Amarillo Biosciences, Inc. Letterhead]



                                    June 2, 2006



United States Securities and Exchange Commission
Division of Corporation Finance
Attn:  Jeffrey Riedler, Assistant Director
100 F Street, NE
Washington, DC 20549-6010

      Re:   SEC Review of Preliminary Proxy Materials;  SEC Letter dated May 12,
            2006  from   Jeffrey   Riedler,   Assistant   Director  to  Amarillo
            Biosciences,  Inc., Re:  Preliminary Proxy Statement on Schedule 14A
            April 25, 2006, revised April 28, 2006; File No. 333-04413

Gentlemen:

      As requested by the above-captioned  letter,  Amarillo  Biosciences,  Inc.
(the "Company") is pleased to submit the following statements:

      1.    The Company is  responsible  for the  adequacy  and  accuracy of the
            disclosure and the proxy material filings;
      2.    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
      3.    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.

                                    Very truly yours,

                                    AMARILLO BIOSCIENCES, INC.



                                    By:____________________________________
                                       Joseph M. Cummins, President and CEO