SecProbe.io

Mail Stop 4720          July 9, 2009  Stephen Anderson Chief Financial Officer OncoGenex Pharmaceuticals, Inc.  1522 217
th Place SE, Suite 100
Bothell, Washington 98021
 Re: OncoGenex Pharmaceuticals, Inc.
  Registration Statement on Form S-3
  Filed June 26, 2009
  File No. 333-160251
 Dear Mr. Anderson:   We have limited our review of your filing to those issues we have addressed in
our comments. After any issues that arise during our examination of the request have
been satisfied, we will consider your request for acceleration of the effective date of the
registration statement.   Please understand that the purpose of our re view 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 any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Incorporation by reference of  Form 8-K filed on 06/26/09

1. We note that you have not incorporated by reference your Form 8-K filed after the
filing of this registrati on statement on June 26, 2009. Because your Form 8-K was
filed during the waiting period for your regi stration statement to become effective,
a statement specifically incorporating this Form 8-K was required in your
disclosure on page 9. Pursuant to  Securities Act Forms Compliance and
Disclosure Interpretations 123.05, “if a regi stration statement does not specifically
incorporate reports filed during the wait ing period, a pre-effective amendment
would be required to incorporate” it. Th erefore, please file a pre-effective
amendment to incorporate your Form 8- K into your registration statement.

Stephen Anderson
OncoGenex Pharmaceuticals Inc.  July 9, 2009 Page 2

* * *
  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 in formation required under
the Securities Act of 1933 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.       Notwithstanding our comments, in the ev ent the company requests acceleration of
the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that:
• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose th e Commission from taking any action with
respect to the filing;
 • the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective,  does not relieve the company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and
 • the company may not assert staff comments a nd the declaration of effectiveness 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 advi sed that the Division of En forcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.     We will consider a written request for acceleration of the effective date of the
registration statement as conf irmation of the fact that t hose requesting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te to the proposed public offering of the
securities specified in the above registration statement.  We will act  on the request and,
pursuant to delegated authority, grant acce leration of the effective date.

 We direct your attention to Rules 460 and 461 regarding requesting acceleration
of a registration statement.  Please allow ad equate time after the filing of any amendment
for further review before submitting a request for acceleration.  Please provide this request at least two business days in a dvance of the requested effective date.

Stephen Anderson
OncoGenex Pharmaceuticals Inc.  July 9, 2009 Page 3
 Please contact Michael McGowan at (202) 551-5797 or me at (202) 551-3715
with any questions.
         S i n c e r e l y ,             J e f f r e y  P .  R i e d l e r          A s s i s t a n t  D i r e c t o r    cc: Randall R. Jones & Christopher L. Doerksen  Dorsey & Whitney LLP  U.S. Bank Center  1420 Fifth Avenue, Suite 3400  Seattle, WA 98101-4010  (206) 903-8800