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Response Letter to SEC Comments on Form 10-KSB for December 31, 2004

Symbollon
Pharmaceuticals, Inc.

37
Loring Drive

Framingham,
MA 01702

(508)
620-7676

Fax:
(508) 620-7111

June 7,
2005

Securities
and Exchange Commission

Division
of Corporation Finance

450 Fifth
Street, N.W.

Judiciary
Plaza

Washington,
D.C. 20549

Attention: Jim
B. Rosenberg

Re: Symbollon Pharmaceuticals,
Inc.

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

            Filed March
31, 2005

            File Number
000-22872

Ladies
and Gentlemen:

The
purpose of this letter is to respond to your comment letter, dated May 31, 2005,
regarding the above referenced company filing. Our responses have been keyed to
your comments.

Financial
Statements

Report
of Registered Independent Accountants, page 25

1.
We supplementally advise the Staff that the Company was not required, nor were
our auditors engaged, to perform an audit of our internal controls for
2004.  Also, our auditors have confirmed for us that they will make the
necessary revisions to their report in future filings, including the
registration statement file #333-124687.

2.
We supplementally advise the staff that our auditors have confirmed for us their
registration is in good standing with the Commonwealth of Massachusetts.
 Our auditors changed their name from "Vitale, Caturano & Company PC"
to "Vitale, Caturano & Company Ltd" effective July 1, 2004 to reflect their
change of legal organization from a professional corporation to a business
corporation.  In connection with this change, the firm was required to
apply for a new license under the new name.  When that new license was
granted in July 2004, the firm then dissolved the old license.

In
connection with responding to your comments, we acknowledge 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.

Please
feel free to contact me at (508) 620-7676, ext. 202 if you have any questions
regarding the above.

Sincerely,

/s/ Paul
C. Desjourdy

Paul C.
Desjourdy

President
and Chief Financial Officer