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CORRESP
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{Letterhead of ID Biomedical Corporation}

September 5, 2005

Via EDGAR

Mary Mast

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. Mast and Ms. Hartz:

The foregoing
letter is in response to the additional comments of the staff (the “Staff”) of
the Securities and Exchange Commission (the “Commission”) relating to the Form
40-F of ID Biomedical Corporation (the “Company”) for the fiscal year ended
December 31, 2004.  The purpose of this
letter is to provide the Staff the proposed textual amendment to the Company’s
Form 40-F.  The Company intends to insert
the language set forth below in an amendment to the Company’s Form 40-F
immediately below the section entitled “Disclosure of Contractual Obligations”.  The Company intends to file this amendment on
Tuesday.  In addition, per our
conversations with the Staff, the Company undertakes in the future to include
the disclosure in the final two paragraphs of the proposed amendment in its
future filings which contain reconciliations of Canadian generally accepted
accounting principles to U.S. generally accepted accounting principles.

Accounting
for Funds Received under Shire Funding Facility

On September 9, 2004, Shire
provided the Company with a funding facility of up to US$100 million.  Under this facility, the Company is committed
to make payments to Shire based on sales or licensing of the products that the
funding was applied to.  Annual minimum
repayments commencing in 2008, in respect of US$30 million of the drawings
related to Flu Advances, is required under the Facility.  Interest accrues on any amount drawn for Flu
Advances at 10% per annum, compounded annually and 20% per annum, compounded
annually, of advances drawn pursuant to Pipeline Advances.

Flu Advances are repayable in
an amount equal to 10% of net sales of specified injectable flu products or 25%
of net licensing income (gross licensing income less unreimbursed direct costs
and expenses) for specified injectable flu products, for all sales or licensing
made outside Canada, to a minimum of $41.8 million (which amount includes
accreted interest to the dates of repayment).
Flu Advances drawn in excess of the amount for

which there is a minimum
repayment obligation are hereinafter called “Excess Flu Advances”.  In addition, with respect to Pipeline
Advances, the Company must pay Shire royalty payments in an amount calculated
as a percentage of net sales or net licensing income for pipeline
products.  The payment terms, only if
sales are achieved on the pipeline products, are as follows:

•                20% of net sales
of pipeline products,

•                50% of net
licensing income achieved on the pipeline products.

The maximum aggregate
repayments shall not exceed US600 million. This maximum aggregate amount
includes accrued interest on the Flu Advances amount as described above and an
amount equal to 20% per year, compounded annually, of the funds drawn pursuant
to Pipeline Advances. In addition to the terms set out above which determine
the repayment amounts, the following factors are noted about the agreement:

a.                           The
Company has not guaranteed, nor does it have a contractual commitment that
assures, repayment of the Excess Flu Advances or Pipeline Advances regardless
of the outcome of the research and development;

b.                          Shire
cannot require the Company to purchase Shire’s interest in the funded research
and development regardless of the outcome of the research and development;

c.                           Shire
does not receive debt or equity securities of the Company upon IDB’s
termination or completion of the funded research and development regardless of
the outcome of the research and development;

d.                          The
Company’s management has not indicated its intention to repay and does not
intend to repay any of the Pipeline Advances prior to successful
commercialization of any pipeline product(s);

e.                           The
Company would not suffer any economic penalty, if it failed to repay any of the
Excess Flu Advances or Pipeline Advances regardless of the outcome of the
research and development;

f.                             A
significant related party relationship between the Company and Shire does not
exist at the time the arrangement was entered into; and,

g.                          The
Company had not essentially completed the research and development projects
before entering into the arrangement.

The Company first evaluates its
repayment obligations under the Shire Funding Facility by considering whether
it has a legal obligation to make repayments regardless of the outcome of the
research and development activities for which the funding by Shire is
applied.  Where such a legal repayment
obligation exists, the Company recognizes amounts received from Shire as a liability
in its consolidated balance sheets.
Interest is accrued on such amounts in accordance with the terms of the
agreement as described above.  The
recognized liability is classified as current or long-term depending on the

period of required or, if
earlier, anticipated repayment.  At December
31, 2004, the Company has recognized $ $37,043,350 (US$30,777,127) as a
long-term liability, which amount is comprised of $36,108,000 (US$30,000,000)
of Flu Advances received and $935,350 (US$777,127)of accrued interest, because
the Company is obligated to repay these funds regardless of the outcome of the
research and development.

For Excess Flu Advances, being
those in excess of the US$30 million minimum repayment obligation, and for
Pipeline Advances, repayment depends solely on the results of the research and
development having future economic benefit.
In accordance with generally accepted accounting principles, the Company
evaluates whether repayment of any of these amounts is probable.  The Company’s evaluation of such probability
is made after considering factors including the progress of the research and
development of the respective products, the likelihood of successful
commercialization, the availability of resources to bring the products to
market, and management’s intention to continue with the respective programs
through to successful commercialization. After evaluation of such factors, the
Company recognizes a liability for repayment to Shire based on its management’s
best estimate that, notwithstanding that repayment is solely contingent upon
future events; it is probable that an obligation has been incurred.  This assessment of probability is reassessed
at each financial reporting date and adjustments to any recorded liability will
be recognized as determinable.

At December 31, 2004, the
Company had received no Excess Flu Advances and US$26,838,275 in Pipeline
Advances.  After making the evaluation of
probability based on the factors set out in the previous paragraph, the Company
determined that a liability should not be recognized for the Pipeline Advances
at December 31, 2004.  In its analysis of
it not being probable that a liability for repayment of the Pipeline Advances
exists, the Company considered the following:

a.                           The
Company is not obligated to repay any of the Pipeline Advances provided by
Shire regardless of the outcome of the research and development - repayment
depends solely on the results of the research and development arrangement
having future economic benefit and not on any other contractual obligation;

b.                          The
Company will require a significant amount of additional capital to fund the
continued research and develop of the pipeline products;

c.                           The Company is subject to
intense competition for skilled personnel and the loss of key personnel or the
inability to attract and retain additional personnel could materially impair
the outcome of the research and development;

d.                          The Company may not be able
to obtain or maintain regulatory approvals that will be necessary to
commercialize our products; and

e.                           Even if the Company is
ultimately able to commercialize the pipeline products, the products may not
gain market acceptance.

As indicated above, the
obligation to repay the Pipeline Advances is dependent solely on the results of
the research and development having future economic benefit, and it is not
probable that such repayment will occur.
In accordance with generally accepted accounting principles, the Company
accounts for funding received for research and development activities where it
is not probable that repayment will occur as a contract to perform services for
others and recognizes revenue by reference to a proportional performance model.

The Company concluded that the
percentage of completion, for purposes of Canadian GAAP,  and proportional performance, for purposes of
U.S. GAAP, method should be applied based on the costs incurred to date
relative to the estimated total costs of the pipeline project(s) that are being
funded.  The costs that are used in the
performance calculation primarily reflect labor hours and direct incremental
costs, used directly in the project, so that the measure reflects actual
performance relative to expected performance.

The Company concluded that the
costs incurred to date are, in fact, both input and output measures since
performance of research undertaken is the only relevant measurement
methodology, or deliverable, with respect to potential very early stage
products.  Costs incurred are considered
by the Company to be an accurate measure of the progress of the specific funded
research and development programs.  This
accounting obtains a consistent result between the percentage-of-completion
method and the proportional performance method and, accordingly, there is no
difference in the revenue recognized between Canadian GAAP and U.S. GAAP.

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 and adds further clarification to the
comments of the Staff.  As we have
discussed, the Company intends to file the amendment to the form 40-F on
Tuesday morning.  Accordingly, the
Company would appreciate expedited consideration by the Staff of this letter and
proposed textual amendment to the 40-F.
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)