SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Via Facsimile and U.S. Mail
Mail Stop 6010

August 22, 2005

Dr. Ramesh C. Pandey
Chief Executive Officer,
Chairman of the Board,
Secretary and Treasurer
Xechem, Inc.
100 Jersey Avenue
Building B, Suite 310
New Brunswick, NJ 08901

Re:	Xechem, Inc.
	Form 10-KSB for Fiscal Year Ended December 31, 2004
	Filed on April 15, 2005
	Form 8-K filed on January 27, 2005

	File No. 000-23788

Dear Dr. Pandey:

      We have limited our review of your filings to those issues
we
have addressed in our comments. In our comments, we ask you to
provide us with information so we may better understand your
disclosure.  After reviewing this information, we may 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 comment 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-KSB for the year ended December 31, 2004

Consolidated Financial Statements

Notes to Consolidated Financial Statements

(9) Investments in Unconsolidated Affiliates

(B) Ceptor Corporation, page F-38

1. We note that you originally purchased all the outstanding
shares
of Ceptor Corporation on January 27, 2004 and by December 31, 2004
you owned 34.3% of Ceptor Corporation.  Please tell us what
specific
transaction occurred in 2004 that reduced your interest in Ceptor
Corporation from 100% to 51.3% to 34.3%.  In addition please tell
us
how you determined the equity method loss of $9.3 million.  Tell
us
when you deconsolidated Ceptor and the date of each transaction in
which your equity percentage changed.  Also, please tell us why
Note
4 to the March 31, 2005 Form 10-Q states that in December 2004 you
owned 51.3%, which appears to conflict with disclosure in the 10-K
that states you owned 34.3% in December 2004.
2. Please tell us why the results of operations and financial
position of Trident have been provided.  Clarify how Trident
relates
to Ceptor and why the information presented is consistent with the
requirements of Rule 310 of Regulation S-B.

Form 8-K filed January 27, 2004

3. We note from your 8-K the Company intended to filed the audited
financial statements of Ceptor pursuant to Rule 3-05 of Regulation
S-
X.  It appears that you have not filed the financial statements.
Please tell us why you have not filed the financial statements.

*    *    *    *

      Please respond to the comments within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
letter
that keys your responses to our comments and provides requested
information.  Detailed letters greatly facilitate our review.
Please
file your letter on EDGAR under the form type label CORRESP.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filing includes all information required under the Securities and
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 comment, 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 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 Joseph Roesler, Staff Accountant, at (202)
551-
3628 or Mary Mast, Senior Accountant, at (202) 551-3613 if you
have
questions regarding the comments. In this regard, do not hesitate
to
contact me, at (202) 551-3679.

								Sincerely,

								For Jim B. Rosenberg
								Senior Assistant Chief
Accountant
??

??

??

??

Dr. Pandey
Xechem, Inc.
Page 1

</TEXT>
</DOCUMENT>