SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

September 7, 2005

Mr. Bruce Fairbairn
Chief Financial Officer
Swiss Medica, Inc.
53 Yonge Street, 3rd Floor
Toronto, Ontario, Canada  M5E 1J3

Re:	Swiss Medica, Inc.
	Form 10-KSB for the fiscal year ended December 31, 2004
	File No. 000-09489

Dear Mr. Fairbairn:

      We have reviewed your filing and have the following comment.
We
have limited our review to only your financial statements and
related
disclosures.  In our comment we ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-KSB for year ended December 31, 2004 filed March 31, 2005

Notes to Financial Statements

Note A - Summary of Significant Accounting Policies

Foreign Currency Translation, page F-9

      Please tell us how your policy for translating assets and
liabilities at current exchange rates during the period complies
with
paragraph 12 of FAS 52 which would require using an end of period
rate. Further, clarify for us how you translate statements of
operations items and how your policy complies with paragraph 12 of
FAS 52.
`
      Please respond to this comment within 10 business days of
the
date of this letter or tell us when you will provide us with a
response.  Please furnish a letter that keys your response to our
comment and provides any requested information.  Detailed letters
greatly facilitate our review.  You should file the letter on
EDGAR
under the form type label CORRESP.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing include all information required under the Securities
Exchange
Act of 1934 and that they have provided all information investors
require for an informed investment decision.  Since the company
and
its management are in possession of all facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

	In connection with responding to our comment, please provide,
in
your letter, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* 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.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Christine Allen, Staff Accountant, at (202)
551-3652 or Kevin Woody, Branch Chief, at (202) 551-3629 if you
have
questions regarding the comment.  In this regard, do not hesitate
to
contact me, at (202) 551-3679.

							Sincerely,

							Jim B. Rosenberg

Senior Assistant Chief Accountant
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Mr. Bruce Fairbairn
Swiss Medica, Inc.
September 7, 2005
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