SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>xechemintitem48-kletter.txt
<DESCRIPTION>COMMENT LETTER DATED 9/21/04, ITEM 4 FORM 8-K, FILING DATE 9/17/04
<TEXT>

Via U.S. Mail and Facsimile

Mail Stop 3-9

	September 21, 2004

Ramesh C. Pandey, Ph.D.
Chief Executive Officer
Xechem International, Inc.
100 Jersey Avenue, Building B, Suite 310
New Brunswick, New Jersey 08901-3279

Re: 	Xechem International, Inc.
	SEC File No.:  000-23788
	Form 8-K filed:  September 17, 2004

Dear Mr. Pandey:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, we will consider your explanation
as to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  In some of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

	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.

1. Please state whether the former accountant resigned, declined to
stand for re-election or was dismissed and the date thereof, as
required by Item 304(a)(1)(i) of Regulation S-B.

2. Please state whether the former accountant`s report contained an
adverse opinion or disclaimer of opinion or was modified as to audit
scope or accounting principles, as required by Item 304(a)(1)(ii) of
Regulation S-B.

3. Please state whether the decision to change accountants was
recommended or approved by: (a) any audit committee of the board of
directors, if the issuer has such committee; or (b) the board of
directors, if the issuer has no such committee, pursuant to Item
304(a)(1)(iii) of Regulation S-B.

4. File an updated letter from your former accountant covering the
changes made in response to the above comments.  File that letter as
Exhibit 16 to the amended Form 8-K, or if not available at the time
of filing, file another amended Form 8-K within ten business days or
within two days of receipt, whichever is earlier.  See Rules
304(a)(3) and 601(b)(16) of Regulation S-B.

Please amend your filing and respond to these comments within five
business days or tell us when you will provide us with a response
prior to the expiration of the five-day period.  Please understand
that we may have additional comments after reviewing your amendment
and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to be
certain that they have provided all information investors require.
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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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 me, at (202) 942-1962 if you have questions regarding
these comments or any other questions.

	Sincerely,

	Sasha Parikh
	Staff Accountant

Xechem International, Inc.
September 21, 2004
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