CAVIT SCIENCES, INC.
                       100 E. Linton Boulevard, Suite 106B
                           Delray Beach, Florida 33483

                                October 11, 2006

Sent Via Fax to (202) 772-9205 and EDGAR


Division of Corporate Finance
U.S. Securities and Exchange Commission
100 F St. N.E.
Washington D.C. 20549
Attn: Mr. Terence O'Brien
      Accounting Branch Chief

RE: Cavit Sciences, Inc.("Registrant")
    Form SB-2/Amedment No. 2
    Filed October 11, 2006
    File Number 333-135740

Dear Mr. O'Brien:

     Pursuant  to Rule 461 under the  Securities  Act of 1933,  as amended  (the
"Act"),  the  undersigned  hereby  requests that the effective date of the above
referenced  Registration  Statement  be  accelerated  so that  the  Registration
Statement may become effective at 08:30 a.m.,  eastern daylight savings time, on
October 16, 2006, or as soon thereafter as  practicable.  By making this request
for acceleration,  the undersigned and the Company hereby acknowledge and accept
their respective  responsibilities under the Act and the Securities Exchange Act
of 1934.

     The Company also acknowledges that:

     1.   Should the  Commission  or the staff,  acting  pursuant  to  delegated
          authority,  declare the filing  effective,  it does not  foreclose the
          Commission from taking any action with respect to the filing;

     2.   The action of the  Commission or 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 in
          the filing; and

     3.   The  Company  may not assert the  declaration  of  effectiveness  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,

Cavit Sciences, Inc.


By: /s/ Colm J. King
   --------------------------
   Colm J. King, President