SecProbe.io

November 9, 2010
 James B. Murphy Vice President and Chief Financial Officer OXiGENE, Inc. 701 Gateway Boulevard, Suite 210
South San Francisco, CA 94080

Re: OXiGENE, Inc.
 Preliminary Proxy Statement on Form PRE14A
Filed November 2, 2010 File No. 000-21990

Dear Mr. Murphy:
 We have reviewed your filing and have the following comment.
 Please respond to this letter by amending your  filing.  If you do not believe our comment
applies to your facts and circumstances or do not believe an amendment is appropriate, please
tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have additional comments.               Preliminary Proxy Statement

 Proposal 1, page 5

1. We note that you are seeking shareholder approv al for a reverse stock split of your issued
and outstanding shares of common stock.  Pleas e revise your disclosu re to describe any
plans, arrangements or understandings relating to the issuance of any additional shares of
authorized common stock that will become av ailable following your reverse stock split.
If you have no such plans, arrangements or understandings, please revi se your disclosure
to state so.   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:

James B. Murphy
OXiGENE, Inc.  November 9, 2010 Page 2

• 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 Bryan Pitko at (202) 551-3203 or me at (202) 551-3715 with any
questions.
Sincerely,
       Jeffrey Riedler
Assistant Director