SecProbe.io

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Shefsky                                          111 E. Wacker Drive, Suite 2800
& Froelich                                               Chicago, Illinois 60601
Attorneys at Law                              Tel 312.527.4000  Fax 312.527.2015
                                                              www.shefskylaw.com

                                                                  Susan W. Wiles

                                                          Direct: (312) 836-4192
                                                       Facsimile: (312) 275-7616
                                                   E-mail: swiles@shefskylaw.com

                                                                IN REFERENCE TO:
                                                                    027779-00001

                                September 2, 2005

Via Facsimile: (202) 772-9217 and EDGAR

Mr. Joseph Roesler
Staff Accountant
Division of Corporation Finance
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

      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, 2004 File No.
               000-23788

Dear Mr. Roesler,

      I am writing on behalf of our client Xechem International, Inc. (the
"Company"), in response to your comment letter dated August 22, 2005. In the
comment letter you requested that we respond to your comments. Pursuant to our
telephone conversation of Monday, August 29, 2005, we are submitting this
response.

      For your convenience, we have reprinted the text of the comments in your
letter of August 22, 2005, in italics, followed by the Company's response.

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

Consolidated Financial Statements

Notes to Consolidate Financial Statements

(9) Investments in Unconsolidated Affiliates

(B) CepTor Corporation, page F-38

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September 2, 2005
Page 2

      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.

      (a) On January 27, 2004, the Company acquired all of the outstanding
capital stock of CepTor Corporation ("CepTor") pursuant to an Agreement and Plan
of Merger ("Merger Agreement"). In conjunction with the Merger Agreement, the
Company issued 6,000 shares (100%) of Class C Series 7 Preferred Stock to the
former shareholders of CepTor, valued at $4,760,000. (See Form 10-QSB/A for the
period ended March 31, 2004, Note [13]).

      On March 31, 2004, the Company entered into an agreement with CepTor and
William Pursley which contemplated that CepTor would take the steps necessary to
effect a stock split. After the split, the Company owned 1,800,000 (adjusted)
shares of CepTor common stock, which represented all of CepTor's then issued and
outstanding stock. During the six months period ending September 30, 2004,
CepTor issued additional shares pursuant to an offering that resulted in the
Company's ownership being reduced to approximately 51.3%.

      On December 9, 2004 CepTor and Medallion Crest Management, Inc. entered
into a merger agreement. Pursuant to the Merger Agreement, Medallion acquired
all of the outstanding capital stock of CepTor in exchange for issuing shares of
Medallion's common stock to CepTor's shareholders at a ratio of 2.165674 shares
of Medallion common stock for each share of CepTor common stock outstanding. As
a result, the former shareholders of CepTor became shareholders of Medallion,
and Medallion changed its corporate name to CepTor Corporation. Following the
merger of CepTor and Medallion, the Company's 1,800,000 shares of CepTor common
stock were converted into 3,898,213 shares of Medallion common stock. The
Company's ownership, however, remained at approximately 51.3%. (See Current
Report on Form 8-K filed on December 14, 2004).

      On December 9, 2004, according to the terms of the Merger Agreement with
Medallion, the Company put and Medallion/CepTor redeemed 103,620 shares of its
Medallion/CepTor stock at $2.50 per share for a total consideration of $259,050
($259,050/$2.50 = 103,620). Following the put/redemption, the Company owned
3,794,593 shares of Medallion/CepTor stock. Simultaneously, Medallion/CepTor was
engaged in an offering, where additional shares of Medallion/CepTor shares were
sold to outside investors. Due to the put/redemption and the offering, the
Company's ownership was further reduced from approximately 51.3% to
approximately 34% (See the Current Report on Form 8-K filed on December 14,
2004).

      On December 27, 2004 the Company put an additional 41,450 shares of its
Medallion/CepTor stock at $2.50 per share for a total consideration of $103,625
($103,625/$2.50 = 41,450). Following the put/redemption, the Company owned
3,753,143 shares of Medallion/CepTor stock, or approximately 34.3%, which
ownership remained substantially the same through December 31, 2004.

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September 2, 2005
Page 3

      (b) CepTor's total loss for the year ending December 31, 2004 was
$15,484,005. The Company allocated its portion of that loss, based on its
percentage ownership at different times during 2004. The Company calculated its
share of net loss from the CepTor ownership at $9,299,526 (round off to
$9,300,000).

      (c) The Company's percentage ownership interest in CepTor changed over the
course of 2004 as described in part 1 (a) of this response and the Company
deconsolidated CepTor accordingly.

      (d) As of December 8, 2004, the Company owned 3,898,213 shares of CepTor
(approximately 51.3%), but as of December 31, 2004, the Company's ownership
interest was reduced to 3,753,143 shares (or, approximately 34.3%). Thus, while
the statements in both the Forms 10-QSB and 10-KSB were technically correct,
both statements should have referred to specific dates in December to be clear.

      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-X.

      Trident is not related to CepTor Corporation or the Company. The name
Trident was inadvertently included in the filing. The filing will be amended to
remove the name Trident.

Form 8-K Filed January 27, 2004

      3. We note from your 8-K the Company intended to file 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.

      At the time of the acquisition, CepTor was in its development stage with
limited operations. Since the date of inception, CepTor had not generated
revenue from the sales of a product. The operations were funded through debt and
equity issuances and grants. CepTor had developed intellectual properties, some
of which were protected under patents. CepTor did not have a current
distribution channel, a customer base or significant plant, property and
equipment. CepTor had a de minimis amount of cash and prepaid expenses and two
notes payable all of which were acquired by the Company.

      Under the guidance of EITF 98-3, it was determined the fair value of the
assets acquired were represented by the intellectual properties received and
therefore the acquisition was deemed an acquisition of assets rather than an
acquisition of a business. In circumstance where the acquired assets do not
constitute a business, Rule 3-05 does not apply, and audited financial
statements were not filed for the acquisition.

<PAGE>

September 2, 2005
Page 4

      The Company acknowledges that it is responsible for the adequacy and
accuracy of the disclosure in the filings; that 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.

                                        Best regards,

                                        SHEFSKY & FROELICH LTD.

                                        /s/ Susan W. Wiles
                                        ----------------------------------------
                                            Susan W. Wiles

cc:      Jim Rosenberg
         Mary Mast
         Ramesh C. Pandey, Ph.D.
         Mitchell D. Goldsmith, Esq.

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