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Letter to the SEC

IVAX CORPORATION

4400 Biscayne Boulevard

Miami, Florida 33137

March 3, 2005

VIA EDGAR AND FACSIMILE

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

Attn: Mr. Jeffrey Riedler, Assistant Director

              Re:
    IVAX Corporation (the “Registrant” or “IVAX”)

Application for Qualification of Indentures on Form T-3 (No. 022-28774)

Ladies and Gentlemen:

     On behalf of the Registrant, the undersigned hereby requests that the effective date of the
Registrant’s above-referenced Application for Qualification of Indentures on Form T-3 be
accelerated so that it becomes effective as early as possible, Monday, March 7, 2005, or as soon
thereafter as practicable.

     In connection with such request, the undersigned, on behalf of IVAX, acknowledges 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 above-referenced filing;

    •
    the actions of the Commission or the Staff, acting pursuant to delegated
authority, in declaring the above-referenced filing effective, does not relieve
IVAX from its full responsibility for the adequacy and accuracy of the disclosure
in the filing; and

    •
    IVAX may not assert the Staff’s declaration of the effectiveness of the
above-referenced filing as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

     This letter will also serve to acknowledge that IVAX understands that the Division of
Enforcement has access to all information IVAX provides to the Staff of the Division of Corporation
Finance in its review of IVAX’ filing or in response to its comments on IVAX’ filing.

    Very truly yours,

IVAX CORPORATION

    /s/ Steven D. Rubin

    Steven D. Rubin, Esq.,

    Senior Vice President and General Counsel