SecProbe.io

October 21, 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.
 Form 10-K
Filed March 29, 2011 File No. 001-33560

Dear Mr. Holliman:
 We have reviewed your filing and have the following comment.
 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 a nd circumstances, please tell us why in your
response.
 After reviewing the information you provide in  response to our comment, we may have
additional comments.
Item 1.  Business

Patents, Licenses and Proprietary Rights, page 6

1. Please revise your disclosure to expand your discussion of your agreements with
University of Texas and Arizona State Univer sity to describe for each the termination
provisions of the agreements and the royalty rates due on sales of future products and all
other material payments made or required to be made pursuant to the terms of each
agreement.  Further, please file a copy  of the license agreement with Washington
University that you have assumed and revise  your disclosure to expand your discussion
of your agreement with Washington University  to include the term ination provisions of
the agreement and the license maintenance paym ents made to date and payable annually
and the royalty rate.  Alternatively, please pr ovide us with a detailed analysis which
supports your conclusion that your business is  not substantially dependent on this license
agreement.

John M. Holliman, III Capstone Therapeutics Corp. October 21, 2011 Page 2

 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 comments, please provi de 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;

 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.

Please contact Karen Ubell, Staff Attorne y, at (202) 551-3873, Jennifer Riegel, Special
Counsel, at (202) 551-3575 or me at ( 202) 551-3715 with any other questions.

Sincerely,
   /s/ Jennifer Riegel for
Jeffrey Riedler
Assistant Director