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{Letterhead of ID Biomedical Corporation}

August 30, 2005

Via
EDGAR

Dana
Hartz

Division
of Corporation Finance

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
DC  20549

  Re:

  ID
  Biomedical Corporation

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

Dear
Ms. Hartz:

                The foregoing letter is in
response to the comment letter of the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) dated August 29, 2005 relating to the
Form 40-F of ID Biomedical Corporation (the “Company”) for the fiscal year
ended December 31, 2004.

                Below we have reprinted the
Staff’s comments and thereunder set forth the related response.

Comment:

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.

Company response:

On
September 9, 2004 , Shire Pharmaceuticals, plc (“Shire”) provided a loan
facility to ID Biomedical Corporation (“IDB or the Company”) of US$100 million which
could be drawn down, at IDB’s discretion over a four year period, to finance
the continued development of early and late stage vaccines acquired by IDB from
Shire. The credit facility can be used to fund the development of an injectable
flu vaccine (“Flu Advances”) and pipeline products (early in the research and
development process) (“Pipeline Advances”) acquired from Shire. Except as
indicated further below, the credit facility is repayable to the extent that income
is generated by the Company of future non-Canadian flu sales or income
generated by the sales or licensing of

the
funded pipeline products. In addition, the credit facility also specifies the
following:

•                  IDB must draw a
minimum of US$30.0 million in Flu Advances;

•                  Interest
accrues on any amount drawn for Flu Advances at 10% per annum, compounded
annually;

•                  Flu Advance repayments
equal to 10% specified net sales of injectable flu products or 25% of net
licensing income for flu products, for all sales or licensing outside Canada;

•                  There is a minimum
repayment requirement totaling US$41.8 million on the flu advances, which
includes accreted interest, beginning in 2008, and continuing through 2017;

•                  In addition to
the US$30 million Flu Advances, US$70 million can be drawn down by ID
Biomedical as either Flu Advances or Pipeline Advances at its discretion;

•                  Additional Flu Advances
accrue interest and are repayable as outlined above.  Pipeline advances accrue interest at 20% per
annum, compounded annually;

•                  Pipeline
repayments are based on a 20% of net sales of pipeline products or a 50% of net
licensing income for pipeline products;

•                  There is no
minimum repayment on the additional US$70 million; and,

•                  The maximum
repayment of Flu Advances and Pipeline Advances  is US$600 million

The
Flu Advances are accounted as long term debt because the Company is obligated
to repay these advances to Shire regardless of the outcome of the research and
development for the Flu vaccines.  For
purposes of the U.S. GAAP reconciliation, amounts received under Flu Advances
are a liability pursuant to FAS 68, paragraph 5.

The
Pipeline Advances are accounted as revenue based on the criteria listed in the
Company’s response to Question 2 below.

Comment:

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

Company response:

Under
U.S. GAAP, the Company records the Pipeline Advances as revenue based on the
guidance in Financial Accounting Standard 68 — Research and
Development Arrangements.  We
believe that FAS 68 represents relevant guidance as the Company will receive
the benefit of research and development activities funded partially by Shire.

For
purposes of the U.S. GAAP reconciliation, we considered the criteria in FAS 68
paragraphs 5 — 9 as indicators as to whether the arrangement on the Pipeline
Advances creates a liability for recognition.
We concluded that the Pipeline Advances do not represent a liability because
repayment depends solely on the results of the research and development
arrangement having future economic benefit and not on any other legal
obligation.  Specifically, we further
note that, regardless of the outcome of the research and development of
pipeline products:

a.               IDB does not
guarantee, or does not have a contractual commitment that assures, repayment of
the Pipeline Advances;

b.              Shire cannot require
IDB to purchase their interest in the research and development of pipeline
products;

c.               Shire does not
receive debt or equity securities of IDB upon IDB’s termination or completion
of the research and development of pipeline products;

d.              IDB’s
management has not indicated its intention to repay and does not intend to
repay any of the Pipeline Advances;

e.               There is no
penalty if IDB does not repay any of the Pipeline Advances;

f.                 Shire and IDB
are not related parties at the time the arrangement was entered into; and

g.              IDB had not
essentially completed the projects for which the funds that are the subject of
the Pipeline Advances are provided.

We
believe that equivalent guidance applies in Canada, both through CICA 1000,
CICA 1100 and CICA 3400, as the advances do not meet the recognition criteria
of a liability defined under Canadian GAAP.

Comment:

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.

Company response:

As
indicated in response to the previous staff comment, the Company considers the
guidance in FAS 68 to be relevant in identifying the accounting for the funding
arrangements.  As the repayment of the
Pipeline Advances is solely based on results of the research and development
arrangement having future economic benefit, FAS 68, paragraph 10, provides that
contract accounting applies.  For
Canadian GAAP purposes, revenue would be recognized by the percentage of
completion method pursuant to CICA 3400.

In
applying contract accounting, we have concluded that we are able to reasonably
estimate the cost and progress of the research and development specifically funded
by the Pipeline Advances. Under the agreement, the payments by Shire for
Pipeline Advances are made based on actual costs incurred by IDB.  Accordingly, we recognize the revenue based
on the costs incurred to date relative to the estimated total costs of the
project(s) that are being funded.  The
costs incurred to date (input measures) are equivalent to the resulting
performance of the research and development activity (output measures) and are
considered by the Company and accurate measure of the progress of the specific
funded research and development programs.
This accounting obtains a result that is consistent with the input
measure under percentage-of-completion method.

Comment:

Tell
us what the minimum annual repayment are and explain to us why you do not
believe the repayment would preclude you from recognizing revenue. Refer to
SFAS 68.

Company response:

The
minimum annual repayments represent minimum repayments for the Flu Advances.
The minimum payments are due January 31st of each year from and including
2008 to and including 2018. The minimum payments are as follows:

2008
US$1,000,000

2009
US$2,000,000

2010
US$3,500,000

2011
US$4,000,000

2012
US$4,000,000

2013
US$5,000,000

2014
US$5,000,000

2015
US$5,000,000

2016
US$5,000,000

2017
US$5,000,000

2018
US$2,300,000

The
repayments are specific to the Flu Advances which the Company accounted for as
long term debt, as described above. As a result, the Company determined that
these minimum payments do not preclude the Company from recognizing revenue on
the Pipeline Advances.

Comment:

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 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 payment and reasons therefore. Please refer to
Financial Reporting Release 72, section IV.

Company response:

The
minimum repayments obligations of the Shire Funding facility are included in
the long term debt section of the contractual obligations table.

Staff comment:

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.

Company response:

This
statement is contained in the Company’s Annual Information Form and was
intended as information to investors on how Shire Pharmaceuticals Group, plc
accounted for Funding Facility. This information originated from Shire
Pharmaceuticals, plc discontinued operations disclosure contained in Shire’s Form
8-K filing dated November 4, 2004.

Comment:

Clarify
if there are any U.S./Canadian GAAP differences related to the above issues.

Company response:

Based
on the conclusions set out above, the Company has determined that there is no
U.S./Canadian GAAP differences related to the above issues.

In
connection with this response letter, the Company hereby confirms and
acknowledges 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.

We hope that the foregoing
adequately responds to the comments of the Staff.  As we have discussed, the Company would
appreciate expedited consideration by the Staff of this comment letter
response.  Please direct any comments or
questions regarding this letter to the undersigned at (425) 892-6105.

  Very
  truly yours,

  ID
  BIOMEDICAL CORPORATION

  By

  \s\
  Richard Bear

  Its

  Chief
  Financial Officer

cc:                                 Christopher H.
Cunningham (Preston Gates & Ellis LLP)

                                                Jonathan
Kallner (KPMG LLP)