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Ivax Corporation

Stearns Weaver Miller

Weissler Alhadeff & Sitterson, P.A.

Miami
      §
      Ft. Lauderdale
      §
      Tampa

March 3, 2005

VIA EDGAR AND FACSIMILE

Jeffrey Riedler, Assistant Director

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C. 20549-0404

    Re:

    IVAX Corporation

Registration Statement on Form S-3

File Number 333-122753

Dear Mr. Riedler:

     This letter is in response to the Staff’s comments regarding the above-referenced filing,
which were provided in your letter to Steven D. Rubin, Esq., dated February 22, 2005.

     Set forth below are responses to the comments in your letter. The numbering of the comments
below corresponds to the numbering set forth in your letter.

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 shareholder 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.

     IVAX has included in the selling security holder table all selling security holders known to
it and has prepared the table based on the information supplied to it by the selling security
holders named in the table.

     Footnote 9, which has been renumbered to footnote 12, explains that the unidentified selling
security holders are either direct purchasers of the notes in a Rule 144A private placement of the
notes completed by IVAX in December 2004 or their transferees, pledgees, donees or successors. To
the extent selling security holders become known to IVAX after the registration statement is
declared effective,

150 West Flagler Street, Suite 2200 § Miami, Florida 33130 § Phone (305) 789-3200 § Fax (305) 789-3395 § www.stearnsweaver.com

Jeffrey Reidler

March 3, 2005

Page 2

IVAX acknowledges that it
must file a post-effective amendment to include selling security holders that
were identified generally in the registration statement.

    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.

     As
of the date the Registration Statement was filed, only one selling security holder had
identified itself as a broker-dealer. The selling security holder was identified as a
broker-dealer in the footnotes to the selling security holders’ table and the “plan of
distribution” section. As of the date Amendment No. 1 to the Registration Statement was filed, an
additional selling security holder had identified itself as a broker-dealer. Such additional
selling security holder has been identified as such in the footnotes to the selling security
holders’ table and the “plan of distribution” section has also been revised to include such selling
security holder. IVAX will provide similar disclosure with respect to any subsequent selling
security holder that identifies itself as a broker-dealer.

    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.

     As of the date the Registration Statement was filed, no selling security holder had identified
itself as an affiliate of a broker-dealer. As of the date Amendment No. 1 to the Registration
Statement was filed, various selling security holders had identified themselves as affiliates of a
broker-dealer. IVAX has identified such selling security holders in footnote 8 and provided the
requested representations in such footnote.

     We have attempted to address each of the comments raised in your letter. If you have any
questions or if we can provide any additional information, please feel free to contact me at (305)
789-3500.

     Thank you for your assistance.

    Very truly yours,

    /s/Alison W. Miller

    Alison W. Miller, Esq.

cc: Song Brandon, Securities and Exchange Commission

§ www.stearnsweaver.com §