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                  VioQuest

                  PHARMACEUTICALS,
                    INC.

                  United
                    States Securities and Exchange Commission

                  450
                    Fifth Street, N.W.

                  Washington,
                    D.C. 20549

                  Attn:
                    Jim B. Rosenberg

                  Senior
                    Assistant Chief Accountant

                  July
                    15,
                    2005

              Re:

                VioQuest
                  Pharmaceuticals, Inc. (the “Company”)

                Form
                  10-KSB for the year ended December 31, 2004

                File
                  No. 000-16686

      Dear
        Mr.
        Rosenberg:

      This
        letter will respond on behalf of the Company to your comment letter dated
        June
        17, 2005 in conjunction with your original comment letter dated April 29,
        2005
        (the "Comment Letter") with respect to the Company's Annual Report on Form
        10-KSB for year ended December 31, 2004 (the “Form 10-KSB”). To facilitate your
        review, we have included in this letter your original comments (in bold)
        followed by our responses, which have been numbered to correspond to your
        letter. In addition, enclosed herewith is a draft of the Company’s amendment to
        the Form 10-KSB, which the Company proposes to file upon the completion of
        your
        review of the Form 10-KSB.

      Item
        6. Management’s Discussion and Analysis of Financial Condition and Results of
        Operations or Plan of Operations

      Results
        of Operations - Years ended December 31, 2004 vs. 2003 page 21

      1. Please
        refer to your response to our prior comment number one. In addition to the
        proposed qualitative discussion you provided in your draft Form 10-KSB/A,
        please
        quantify the impacts of the qualitative factors disclosed. Refer to Item
        303(b)(1) of Regulation S-B.

      Response:
        As
        suggested, in the proposed draft amendment, the Company has expanded the
        discussion of revenues to include not only a more robust discussion of the
        qualitative factors disclosed, but has also quantified the impacts of those
        factors where applicable. Our revenues for the year ended December 31, 2004
        were
        $1,485,148 as compared to $669,036 for the year ended December 31, 2003.
        For the
        year ended December 31, 2004, approximately 8% of total revenue was derived
        from
        the amortization of option fee income pertaining to the licensing of our
        intellectual property and 92% of total revenue was derived from customized
        process development services sold to third parties
        (accounting for 47% of total 2004 revenue), sales of our catalysts and ligands
        (34% of total 2004 revenue), and feasibility screening reports provided to
        clients (11% of total 2004 revenue). The overall increase in 2004 revenue
        is
        attributable primarily from a 75% increase from 2003 revenue from contracts
        for
        customized process development services. In addition, the increase in 2004
        revenues is also attributable to our selling and production capabilities
        transitioning from an academic Research and Development sales volume level,
        to a
        commercial sales volume quantity level for its ligands, catalysts, and
        customized process development services. As a result, revenue from sales
        of
        catalysts and ligands increased five fold from 2003 because we were able
        to sell
        greater quantities and a wider variety of our proprietary ligands and catalysts
        to an expanded customer base that more than doubled in 2004 compared to 2003.
        Revenue from feasibility screening in 2004 also increased three fold from
        2003
        levels. We anticipate that sales of our proprietary ligands and catalysts
        and
        customized process development
        services
        will continue to comprise a greater percentage of our revenues in the future
        as
        we expand our manufacturing capabilities.

        VioQuest
          Pharmaceuticals, Inc.

        Princeton
          Corporate Plaza, Suite E

        7
          Deer Park Drive, Monmouth Junction, NJ 08852 USA

        Telephone:
          +1 732 274 0399 Fax: +1 732 274 0402

      Our
        gross
        profit decreased for the year ended December 31, 2004, as compared to December
        31, 2003, as a result of our 2004 revenues being significantly derived from
        the
        sale of ligands and catalysts products and services versus a greater percentage
        of revenues derived from option fee income pertaining to a license agreement
        for
        the fiscal year ended 2003. For
        the
        year ended December 31, 2003, approximately 20% of total revenue was derived
        from the amortization of option fee income and 80% of total revenue was
        comprised of sales or our ligands.

      See
        page
        21 of the draft amended Form 10-KSB.

      2. Please
        refer to your response to our prior comment number three. Please provide
        us your
        analysis under SFAS 2 of why these costs are research and development
        costs.

        Response:
        Please
        refer to our original response letter dated April 29, 2005 in conjunction
        with
        the our expanded response related to Research and Development costs.

      Research
        and Development costs include the following expenses related to the efforts
        dedicated by the Company to develop its proprietary technology: (1) the Company
        sponsoring four post doctorates at Penn State University of approximately
        $330,000, including salaries, lab supplies and chemicals used by the post
        doctorates to analyze, develop, and document the procedures used to determine
        the future viability of the Company’s proprietary technologies; (2) costs
        incurred to purchase laboratory chemicals, such as gases, solvents and
        solutions, in the amount of approximately $310,000, which chemicals were
        dedicated to
        run
        pilot test programs and perform analytical studies and produce reports to
        determine the capabilities of its technical laboratory facilities to produce
        its
        technologies;
        (3)
        laboratory supplies, such as glassware, syringes, vials safety equipment,
        of
        approximately $255,000, which were also used in the formulation, evaluation
        and
        analysis to run pilot test programs and perform analytical studies and produce
        reports to determine the capabilities of its technical laboratory facilities
        to
        produce its proprietary technologies for future use. The Company transitioned
        from a research and development facility to a commercial production facility
        during the latter part of the third quarter of 2004. Management believes
        these
        research and development costs incurred are appropriately classified as R&D
        as they relate to testing the feasibility of it proprietary products, through
        analyzing our laboratory’s technical and production capabilities, as the costs
        specifically relate to test pilot programs of our proprietary technology
        which
        include the sponsoring of post doctorates, the purchases of additional
        laboratory materials and supplies such as chemicals, solvents, glassware
        during
        2004 are appropriately classified as R&D.

      Critical
        Accounting Policies and Estimates, page 24

      Revenue
        Recognition, page 24

      3. We
        note your proposed disclosure in your draft Form 10-KSB/A as a result of
        our
        prior comment six. Please expand your disclosure to address the judgments
        and
        estimates inherent to your determination of net revenues. Additionally, please
        clarify for us, and in the document whether those estimates relate to sales
        returns, discounts or allowances. If your estimates do relate to those items
        that reduce your net revenue, please revise your disclosures to address the
        information we requested in our initial comment.

      Response:
        The
        Company has revised its discussion of critical accounting policies and
        estimates, as requested. In determining net revenues, the Company recognizes
        revenues based upon shipments and the invoicing of its products and services.
        Accordingly, the Company does not have a sales allowance, sales discount
        or
        sales returns reserve policy in place and, accordingly, does not make any
        material judgments or estimates relating to net revenues. The Company had
        one
        return during the fiscal year 2004 for approximately $25,000, which was
        reshipped in the first quarter of 2005. The return was a result of the customer
        inquiring if the Company were able to rework the materials originally sent
        by
        providing a higher purity level. See pages 24 - 25.

      Consolidated
        Statements of Operations, page F-4

      4. Refer
        to your responses to comments eight and nine. We believe that your proposed
        revisions should be made in the amendment to your December 31, 2004 Form
        10-KSB.

      Response:
        Subject
        to additional comments from the Staff, the Company will file an amendment
        to its
        2004 Form 10-KSB including the revisions proposed in the Company’s responses to
        prior comments 8 and 9.

      Note
        5. Rights to Intellectual Property - F-14

      5. Please
        refer to your responses to our prior comment number 11. Please include your
        proposed disclosures in an amendment to your December 31, 2004 10-KSB.
        Specifically address in this policy how the outcome of defending your patents
        impacts the amounts capitalized. It increased the balance of the capitalized
        patent amount. Also include a discussion of the specific items that resulted
        in
        the increases in each the current period [sic].

      Response: Management
        has determined that the future economic benefits derived from the capitalized
        patent costs will exceed their carrying value. The capitalized amounts of
        intellectual property are comprised of domestic and international patent
        filing
        fees, patent enhancement fees, in addition to legal application and prosecution
        fees associated to the defense of the Company’s patents. The gross patent cost
        increase for the year ended 2004 of approximately $195,000 are fees directly
        charged by our patent attorneys for a combination of domestic and foreign
        legal
        patent application filing fees, and the prosecution filing fees in the
        successful defense of our patents. The Company will amend its December 31,
        2004
        10-KSB filing to include the response as stated above related to the
        capitalization and increase of patent costs.

      *
        *
        *

      Additionally,
        as you requested, we acknowledge 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 proceeding
                initiated by the Commission or any person under the federal securities
                laws of the Untied States.

      Upon
        review of this response letter, if you have any additional questions or comments
        concerning the Company or the Form 10-KSB, or if you wish to discuss any
        the
        responses, please do not hesitate to contact the undersigned at (732) 274-0399,
        ext. 17.

      Yours
        truly,

      /s/
        Brian
        Lenz

      Brian
        Lenz, CPA

      Chief
        Financial Officer