SecProbe.io

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Mail Stop 6010

Via Facsimile and U.S. Mail

May 27, 2005

Mr. David H. Kirske
Vice President and
Chief Financial Officer
Helix Biomedix, Inc.
22122-20th Avenue Southeast, Suite 148
Bothell, WA 98021

      Re:	Helix Biomedix, Inc.
		Form 10-KSB for Fiscal Year Ended December 31, 2004
	            File No. 033-20897

Dear Mr. Kirske:

      We have limited our review of your filing to those issues we
have addressed in our comments.  Where indicated, we think you
should
revise your document in response to these comments.  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 information so we may better understand
your
disclosure.  After reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Item 6. Management`s Discussion and Analysis or Plan of Operation,
page 17

Plan of Operation, page 18
1. Please expand your disclosure by referring to the Division of
Corporation Finance "Current Issues and Rulemaking Projects
Quarterly
Update" under section VIII - Industry Specific Issues - Accounting
and Disclosure by Companies Engaged in Research and Development
Activities.  You can find it at the following website address:
http://www.sec.gov/divisions/corpfin/cfcrq032001.htm#secviii.

Please disclose the following information for each of your major
research and development projects:

a. The current status of the project;
b. The costs incurred during each period presented and to date on
the
project;
c. The nature, timing and estimated costs of the efforts necessary
to
complete the project;
d. The anticipated completion dates;
e. The risks and uncertainties associated with completing
development
on schedule, and the consequences to operations, financial
position
and liquidity if the project is not completed timely; and,
f. The period in which material net cash inflows from significant
projects are expected to commence.

Regarding b., if you do not maintain any research and development
costs by project, disclose that fact and explain why management
does
not maintain and evaluate research and development costs by
project.
Provide other quantitative or qualitative disclosure that
indicates
the amount of the company`s resources being used on the project.

Regarding c. and d., disclose the amount or range of estimated
costs
and timing to complete the phase in process and each future phase.
To
the extent that information is not estimable, disclose those facts
and circumstances indicating the uncertainties that preclude you
from
making a reasonable estimate.

Item 7. Financial Statements, page 22

Notes to Financial Statements, page 31

Note 1 - Summary of Significant Accounting Policies, page 31

Intangibles, page 33
2. Please explain to us how your policy to capitalize patent costs
and defer amortization until issuance of the patents complies with
GAAP.  Tell why recognizing these costs as an expense prior to the
successful outcome of the application is not appropriate

Revenue Recognition, pages 33-34
3. Please refer to your revenue recognition policy for
nonrefundable
upfront fees when no future obligations exist.  Please tell us and
expand your disclosure to clarify the nature of the products
delivered or services performed that represent the culmination of
a
separate earnings process.  Please refer to revenue recognition of
nonrefundable up-front fees discussed in SAB Topic 13A.3.
Disclose
the method used to recognize revenue for payments that are
deferred.

Research and Development, page 34

4. Tell us how your policy to expense research and development
costs
associated with collaborative agreements at the earlier of when
amounts are due or when services are performed complies with the
requirement of paragraph 12 of SFAS 2 to expense research and
development costs when incurred.

*    *    *    *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  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 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.

	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.
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.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

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

      You may contact Todd Sherman, Staff Accountant, at 202-551-
3665
or Don Abbott, Senior Staff Accountant, at 202-551-3608 if you
have
questions regarding the comments.  In this regard, do not hesitate
to
contact me, at (202) 551-3679.

								Sincerely,

								Jim B. Rosenberg
							Senior Assistant Chief
      Accountant
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David H. Kirske
Helix Biomedix, Inc.
May 27, 2005
Page 4

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