SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

August 29, 2005

Mr. Richard Bear
Principal Financial Officer
ID Biomedical Corporation
1630 Waterfront Center
200 Burrard Street
Vancouver, British Columbia
Canada, V6C 3L6

Re:	ID Biomedical Corporation
	Form 40-F for Fiscal Year Ended December 31, 2004
	Filed April 1, 2005
	File No.  000-20390

Dear Mr. Bear:

      We have limited our review of your filing to those issues we
have addressed in our comment.  In our comment, we 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 comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 40-F for the fiscal year ended December 31, 2004

Financial Statements

Note 14. Long-term Debt

(a) Funding Facility, page 109

1. We note that you record some of the advances from Shire as
revenue.  It appears that these payments will be repayable in the
future.  Refer also to the "Shire LLC Credit Facility" in Exhibit
1
on page 44 and address the following comments in disclosure-type
format:

a. Please tell us how you determined that a portion of the credit
facility should be accounted for as debt and a portion as revenue.
Provide us more information regarding the nature of each type of
advance.
b. For U.S. GAAP and Canadian GAAP purposes, please tell us why
you
believe recording any of the advance as revenue is appropriate.
In
your analysis, please cite the specific U.S. GAAP accounting
literature that supports your policy.
c. Tell us the basis for using the percentage of completion method
for revenue recognition.  Under U.S. GAAP, recognizing the revenue
under the percentage of completion method is not appropriate
because
it assumes you are using an input measure, whereas it appears you
should be using an output measure.
d. Tell us what the minimum annual repayments are and explain to
us
why you do not believe the repayments would preclude you from
recognizing revenue.  Refer to SFAS 68.
e. It does not appear that the minimum annual repayments are
included
in the contractual obligation table.  Please clarify for us
whether
these payments meet the criteria as a purchase obligation per the
Instructions to the Form 40-F.  If they are not included, tell us
your basis for a) excluding them from the table and b) not
providing
disclosure to the table informing investors that it excludes these
types of payments and the reasons therefore.  Please refer to
Financial Reporting Release 72, section IV.
f. Please tell us what you mean when you state that $70 million of
the $100 funding commitment from Shire was written off under
generally accepted accounting principles because repayment was
uncertain.  Tell us how this was accounted for in the financial
statements and why you believe your accounting treatment is
appropriate.
g. Clarify if there are any U.S./Canadian GAAP differences
relating
to the above issues.

*    *    *    *

      Please provide us the information requested within 10
business
days or tell us when you will provide us with a response.  Please
furnish a cover letter with your response that keys your response
to
our comment.  Detailed cover letters greatly facilitate our
review.
Please file your letter on EDGAR under the form type label
CORRSEP.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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 comment, please provide,
in
your letter, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure 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
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 comment on your filing.

      You may contact Dana Hartz, Staff Accountant, at (202) 551-
3648
or Mary Mast, Review Accountant, at (202) 551-3613 if you have
questions regarding the comment.  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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Mr. Richard Bear
ID Biomedical Corporation
August 29, 2005
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