SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 6010

							September 2, 2005

Daniel Greenleaf
President and Chief Executive Officer
Vioquest Pharmaceuticals, Inc.
7 Deer Park Drive, Suite E
Monmouth Junction, New Jersey 08852

Re:	Revised Proxy Statement on Schedule 14A
    	File No. 0-16686
	Filed August 19, 2005

Dear Mr. Greenleaf:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should amend your proxy statement.
If
you disagree, we will consider your explanation as to why our
comment
is inapplicable or a revision is unnecessary.  Please be as
detailed
as necessary in your explanation.  In some of our comments, we may
ask you to provide us with supplemental information so we may
better
understand your disclosure.  After reviewing this information, we
may
or may not 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.

Revised Schedule 14A

Tandy Representation
1. In our first comment letter we asked for the following
representation to be given in connection with your response to our
comments:

* 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 in the filings reviewed by the staff 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.

	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 connection with our review of
your
filing or in response to our comments on your filing.

We note that you did not provide a letter acknowledging the
language
included in this comment.  Please advise us or provide us with
this
representation in your next response letter.

"Following the Merger, if we are unable to hire additional
qualified
. . . .," page 15
2. We note your response to comment 21 and your revised
disclosure.
Please quantify approximately how many additional employees you
expect to hire in the areas you have identified in this risk
factor
as well as the approximate time frame in which you plan to hire
these
additional employees. If you are unable to quantify the
approximate
number of additional employees, please so state and include the
reasons you cannot provide the amount.

Federal Income Tax Consequences of Reincorporation, page 29
3. We note your response to comment 30 and reissue the comment.
Please state whether or not you will have or will obtain a tax
opinion regarding the reincorporation. If you have not or are not
obtaining an opinion, state the basis for the disclosure in the
tax
section.

The Merger, page 40
4. We note your response to comment 35 and have received your
application for confidential treatment with respect to Greenwich`s
agreements with the Cleveland Clinic Foundation and the University
of
South Florida Research Foundation, respectively. We are currently
reviewing your application and will issue any comments in a
separate
letter.

Selected Historical Financial Data, page 60

5. Refer to your response to comment 66.  We note that you added
certain disclosures as "Pro forma information."  It is not clear
what
this amount represents.  Your presentation also does not address
the
requirement that this be presented in columnar format to clearly
indicate what these represent and the impact of the proforma
numbers.
Please revise your disclosure to clarify what this "Pro forma
information" is and present it in the described format.  To the
extent that pro forma EPS differs from the EPS presented here,
disclose that in a similar format.  Consider the need to disclose
this information in summary format for VioQuest here as well to
better understand what is being presented on a pro forma basis.
Refer to Item 3(f) of the instructions to Form S-4.

Pro Forma Financial Information, page 68

(1) Description of Transaction and Basis of Presentation, page 73

6. Please refer to your response to our prior comment 68.   We
recognize that this is a preliminary valuation.  However the
statement of this fact does not address why you feel that the
payment
of contingent consideration discussed in the second to the last
paragraph on page 73 will allow you to increase the charge to
IPR&D
when made.  Please explain to us why you feel that this apparent
residual valuing methodology is appropriate.

Financial Statements - Greenwich Therapeutics, Inc., page C-1

Statements of Cash Flows, page C-6

7. Please refer to your response to our prior comment number 70.
Please clarify on the face of the statement of cash flows, or in a
note to the financial statements that this transaction does not
represent an actual advance to the company, but instead represents
a
non-cash transaction where the related party pays directly the
expenses.  Also clarify in your disclosure in note 7 that you did
not
actually physically receive these advances as the current wording
seems to imply, but that the related party made additional
payments
for your benefit.  Refer to paragraph 32 of SFAS 95.

*	*	*

	As appropriate, please amend your filing in response to these
comments.  You may wish to provide us with marked copies of the
amendment to expedite our review.  Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested supplemental information.  Detailed cover letters
greatly facilitate our review.  Please understand that we may have
additional comments after reviewing your amendment and responses
to
our comments.

You may contact Tabatha Akins at (202) 551-3658 or James Atkinson,
Accounting Branch Chief at (202) 551-3674 if you have questions
regarding comments on the financial statements and related
matters.
Please contact Song P. Brandon at (202) 551-3621, John Krug at
(202)
551-3862or me at (202) 551-3710 with any other questions.

							Sincerely,

							Jeffrey Riedler
							Assistant Director

cc:	Christopher J. Melsha, Esq.
	Kristen J. Wilcox, Esq.
	Maslon Edelman Borman & Brand, LLP
	3300 Wells Fargo Center
	90 South Seventh Street
	Minneapolis, Minnesota 55401

??

??

??

??

1

</TEXT>
</DOCUMENT>