SecProbe.io

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                               SWISS MEDICA, INC.
                           53 YONGE STREET, 3rd FLOOR
                            TORONTO, ONTARIO, CANADA

                                                              September 8, 2005

VIA FAX AND EDGAR

Ms. Christine Allen Division of Corporate Finance U.S. Securities & Exchange
Commission Washington, D.C. 20549

Re:  Swiss Medica, Inc.
     File No. 000-09489
     Form 10-KSB for Year Ended December 31, 2004

Dear Ms. Allen:

      This will acknowledge receipt of your letter of comment dated September 7,
2005 with regard to the above referenced filing. Our response references your
comment as follows:

Although the Registrant is located in Canada, the Registrant's management has
determined to use US Dollar as its functional and reporting currency based upon
consideration of economic and other factors. The books of record are
consistently maintained in US Dollar. Accordingly, translation of functional
currency into the reporting currency is obviated.

While the Registrant believes its accounting policy for foreign currency
translation is reasonable and in accordance with U.S. generally accepted
accounting principles, the Registrant will revise in its future filings its
disclosure of general accounting policy for foreign currency translation as
follows:

Foreign Currency Translation

The Company translates the foreign currency financial statements in accordance
with the requirements of Statement of Financial Accounting Standards No. 52,
"Foreign Currency Translation." Assets and liabilities are translated at the
rates of exchange at the balance sheet date, and related revenue and expenses
are translated at average monthly exchange rates in effect during the period.
Resulting translation adjustments are recorded as a separate component in
stockholders' equity. Foreign currency transaction gains and losses are included
in the statement of income.

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The Company acknowledges that:

      The Company is responsible for the adequacy and accuracy of the disclosure
in the filing:

      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 proceedings
initiated by the commission or any person under the federal securities laws of
the United States.

      We thank you in advance for your assistance in this matter. If you have
any questions or additional comments, please do not hesitate to contact me at
(416) 868-0708.

                                              Yours truly,

                                              Swiss Medica, Inc.

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