SecProbe.io

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Mail Stop 3-09

									February 22, 2005

Steven D. Rubin, Esq.
Senior Vice President
General Counsel and Secretary
IVAX Corporation
Miami, FL  33137

Re:	IVAX Corporation
	Registration Statement on Form S-3
	File Number 333-122753

Dear Mr. Rubin:

      This is to advise you that we have limited our review of the
above referenced registration statement to your selling
shareholder
section and the issues identified below. We will make no further
review of this filing.

Selling Shareholder, page 25
1. We note that approximately 78% of the selling security holders
are
currently unidentified.  Registrants are generally required to
name
all selling security holders known at the time that a resale
registration statement is filed and goes effective.  Please file a
pre-effective amendment to the registration statement that
identifies
all of the selling security holders and provides the information
required by Item 507 of Regulation S-K, including the amount of
securities owned by each selling security holder prior to the
offering and the amount to be offered for the security holder`s
account, as well as the amount and (if one percent or more) the
percentage of the class to be owned by such security holder after
completion of the offering. In the alternative, you may describe
unknown, unidentified selling security holders by class, e.g.
former
shareholders of a merged company, for an identified amount of
securities registered for resale.  You must then specifically
identify the previously unidentified selling security holders that
were described generally in the registration statement, along with
the other information required by Item 507, by post-effective
amendment as the selling security holders become known to the
registrant.
2. We note that some of the selling security holders may be
broker-
dealers.  If these entities obtained these securities other than
as
compensation for underwriting services, then they will be deemed
to
be underwriters under the Securities Act.  In that case, please
revise your disclosure to include any such parties as underwriters
in
the "plan of distribution" section and other sections of the
prospectus as appropriate.
3. If any of the selling security holders are affiliates of
broker-
dealers, they should be so identified.  In addition, please revise
your disclosure to include the following representations:

* The selling security holder purchased in the ordinary course of
business; and
* At the time of the purchase, the selling security holder had no
agreements or understanding to distribute the securities.

If you are unable to make these statements in the prospectus,
please
revise the prospectus to state the seller is an underwriter.

      *	*	*

      Once you have cleared our comments, we will act upon any
request for acceleration of the effective date of the Form S-3 and
pursuant to delegated authority, grant acceleration of the
effective
date.  We will consider your request for acceleration as a
confirmation of the fact that you are aware of your
responsibilities
under the Securities Act of 1933 and the Securities Act of 1934 as
they relate to the proposed public offering.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* 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;

* the action of the Commission or the 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 of the disclosure in the filing; and

* the company may not assert this action 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 connection with our review of
your
filing or in response to our comments on your filing.

	We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      Please contact Song P. Brandon at (202) 942-2831 with any
other
questions.

Sincerely,

Jeffrey Riedler
Assistant Director

cc:	Alison W. Miller, Esq.
	Stearns Weaver Miller Weissler
	Alhadeff & Sitterson, P.A.
	150 West Flagler Street, Suite 2200
	Miami, FL  33130

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