SecProbe.io

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Mail Stop 6010

									May 31, 2005

Paul Desjourdy
President and Chief Financial Officer
Symbollon Pharmaceuticals, Inc.
37 Loring Drive
Framingham, MA 01702

Re:  	Symbollon Pharmaceuticals, Inc.
      Form 10-KSB for the fiscal year ended December 31, 2004
      Filed March 31, 2005
      File Number:  000-22872

Dear Mr. Desjourdy:

      	We have reviewed your filing and have the following
comments.  We have limited our review of the above referenced
filing
to only those issues addressed. In our comments, we ask you to
provide us with supplemental information so we may better
understand
your disclosure.  Please provide us the supplemental information
requested within 10 business days of the date of this letter or
tell
us when you will provide a response prior to the expiration of the
10-day period.  Please furnish a letter with your supplemental
responses that keys your response to our comment.  Detailed
letters
greatly facilitate our review.  You should file the letter on
EDGAR
under the form type label CORRESP.  Please understand that we may
have additional comments after reviewing your response to our
comment.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the fiscal year ended December 31, 2004

Financial Statements

Report of Registered Independent Accountants, page 25
1. It appears that the scope paragraph to the audit report has
been
revised to include the suggested language from AU Section 9508.17.
If
such a reference is made, we believe that it should conform to the
suggested language outlined in Center For Public Company Audit
("CFPCA") Alert #46, which can be obtained at
http://cpcaf.aicpa.org/.  Please confirm to us that the Company
was
not required nor were your auditors engaged to perform an audit of
the Company`s internal controls. Further confirm that, in audit
reports included in future filings including the registration
statement file #333-124687, your auditors will include, all of the
suggested language in CFPCA Alert #46 including the statement that
"the company is not required to have, nor were we engaged to
perform,
an audit or its internal controls over financial reporting," or
alternatively, will delete the two sentences beginning "An audit
includes consideration...." currently from the report.
2. It appears that the license of your auditor may have expired on
June 30, 2004.  Rule 2-01(3)(a) of Regulation S-X requires that a
certified public accountant be registered and in good standing
under
the laws of the place of their principal office.  Please confirm
the
status of the license.

	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 all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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 connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging 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.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Vanessa Robertson, Staff Accountant, at
(202)
551-3649 or Kevin Woody, Accounting Branch Chief, at (202) 551-
3629
if you have any questions regarding the comments.  In this regard,
do
not hesitate to contact me, at (202) 551-3679.

								Sincerely,

								Jim B. Rosenberg
								Senior Assistant Chief
Accountant
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Paul Desjourdy
Symbollon Pharmaceuticals, Inc.
Page 3

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