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SEC Company Response from Oncotelic Therapeutics, Inc. (OTLC) (CIK 0000908259) (OTLC) — Apr 28, 2010

Oncotelic Therapeutics, Inc. (OTLC) (CIK 0000908259)
Date: April 28, 2010 · CIK: 0000908259 · Accession: 0000950123-10-039844

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File numbers found in text: 333-165826

Date
April 28, 2010
Author
James B. Murphy
Form
CORRESP
Company
Oncotelic Therapeutics, Inc. (OTLC) (CIK 0000908259)

Letter

VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Attention: Jennifer Riegel, Esq. RE: OXiGENE, Inc. Registration Statement on Form S-3 (File No. 333-165826) Acceleration Request

Dear Ms. Riegel:

Pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, OXiGENE, Inc. (the “Company”) hereby respectfully requests that the effectiveness of the above-captioned Registration Statement on Form S-3 be accelerated to Thursday, April 29, 2010, at 4:00 p.m. Eastern Time, or as soon as practicable thereafter.

The Company acknowledges 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.

The cooperation of the staff in meeting the timetable described above is very much appreciated.

Any questions regarding this request should be addressed to Asya S. Alexandrovich, Esq., at Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., One Financial Center, Boston, Massachusetts 02111, telephone (617) 210-6820.

Very truly yours,
OXiGENE, Inc.

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CORRESP
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corresp

OXiGENE, Inc.

701 Gateway Blvd., Suite 210

South San Francisco, California 94080

April 28, 2010

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Jennifer Riegel, Esq.

    RE:

    OXiGENE, Inc.

    Registration Statement on Form S-3 (File No. 333-165826)

    Acceleration Request

Dear Ms. Riegel:

     Pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended,
OXiGENE, Inc. (the “Company”) hereby respectfully requests that the effectiveness of the
above-captioned Registration Statement on Form S-3 be accelerated to Thursday, April 29, 2010, at
4:00 p.m. Eastern Time, or as soon as practicable thereafter.

     The Company acknowledges 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.

     The cooperation of the staff in meeting the timetable described above is very much
appreciated.

     Any questions regarding this request should be addressed to Asya S. Alexandrovich, Esq., at
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., One Financial Center, Boston, Massachusetts
02111, telephone (617) 210-6820.

    Very truly yours,

OXiGENE, Inc.

    /s/ James B. Murphy

    By:  James B. Murphy

    Its: Vice President and Chief
Financial Officer

    cc:

    Jeffrey P. Riedler, Esq., Securities and Exchange Commission

    Jonathan L. Kravetz, Esq., Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

    Megan N. Gates, Esq., Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.