SecProbe.io

June 14, 2011

Via E-mail
John M. Holliman, III
Executive Chairman
Capstone Therapeutics Corp.
1275 West Washington Street, Suite 101 Tempe, AZ 85281

Re: Capstone Therapeutics Corp.
Item 4.01 Form 8-K   Filed June 10, 2011
  File No. 001-33560

Dear Mr. Holliman:
 We have reviewed your filing and have the fo llowing comment.  In our comment, we ask
you to provide us with information so we may better understa nd your disclosure.
 Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response.   If you do not believe our comment applies to your facts and ci rcumstances or do not believe an amendment is
appropriate, please tell us why in your response.  Please furnish us a letter on EDGAR under the
form type label CORRESP that keys  your response to our comment.
 After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have additional comments.

Item 4.01

1. Please revise the last paragraph to specify the subsequent interim period as the interim
period through the date of engagement whic h was June 10, 2011.  Your current disclosure
only goes through June 6, 2011.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 responding to our comment, please provide a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

John M. Holliman, III
Capstone Therapeutics Corp.
June 14, 2011
Page 2

  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 federa l securities laws of  the United States.

You may contact Vanessa Robe rtson, Staff Accountant, at (202) 551-3649 if you have
any questions regarding the comment.  In this re gard, do not hesitate to contact me, at (202) 551-
3651.
Sincerely,
  /s/ Joel Parker
        J o e l  P a r k e r          A c c o u n t i n g  B r a n c h  C h i e f