SecProbe.io

August 14, 2013

Via E -mail
Dr. Peter Langecker
Chief Executive Officer
OXiGENE, Inc.
701 Gateway Blvd., Suite 210
South San Francisco, California 94080

Re: OXiGENE, Inc.
  Registration Statement on Form S-1
Filed  August 8, 2013
  File No.  333-190464

Dear Dr. Langecker :

We have limited our review of your registration statement to those issues we have
addressed in our comment .

Please respond to this letter by amending your registration statement and providing the
requested information .  Where 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 registration statement and the information you
provide in response to this comment , we may have  additional comments.

General

1. Although Rule 430A of the Securities Act of 1933 perm its registrants to omit certain
pricing -related information from a registration statement t hat is declared effective, your
filing must include the amount of  securities to be offere d in a pre -effective amendment.
Accordingly, p lease revise your disclosure to specify :

 The number of units to be sold;
 The number of shares of common stock per unit;
 The number of warrants per unit;  and
 The number of shares of common stock issuable  upon exercise of the warrants.

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 the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in

Dr. Peter Langecker
OXiGENE, Inc.
August 14, 2013
Page 2

 possession of all facts relating to a company’s disclosure, they a re responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company  may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of  the
registration statement.

Please contact Matthew Jones  at (202) 551 -3786, Bryan Pitko  at (202) 551 -3203 , or me at
(202) 551 -3715 with any questions.

Sincerely,

 /s/ Bryan J. Pitko for

Jeffrey P. Riedler
Assistant Director

cc:  Megan Gates
 Mintz, Levin, Cohn, Ferris ,
Glovsky and Popeo, P.C.
 One Financial Center
 Boston, MA 02111