SecProbe.io

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Mail Stop 0309

							April 6, 2005

Antonio Milici, M.D., Ph.D.
President, Chief Executive Officer and Director
GeneThera, Inc.
3930 Youngfield Street
Wheat Ridge, Colorado 80033

Re:	GeneThera, Inc.
	Registration Statement on Form SB-2
	File Number 333-123138

Dear Dr. Milici:

	This is to advise you that we are not conducting a full
review
of the above registration statement.  However, we have performed a
limited review of it.  We note the discussion about 0711005 B.C.
Ltd.
in the Recent Developments section on page 1.  As this entity
appears
to be among the most highly compensated entities your company
contracts with, please describe this consultant`s expertise and
qualifications.  Also, in the Selling Shareholders section on page
37, please identify 0711005 B.C. Ltd.`s controlling person.

	Furthermore, we will be reviewing the accounting disclosure
in
your Form 10-KSB for the period ended December 31, 2004.  You will
receive our accounting comments under separate cover.  All
comments
will need to be fully resolved before we take final action on the
registration statement.

	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
for
an informed 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 event 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 pursuant to delegated
authority, declare the filing effective, it does not foreclose the
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 this action 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 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 a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate 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
acceleration of the effective date.

	You may contact Dana Hartz at (202) 942-2976 or Joel Parker
at
(202) 824-5487 if you have questions regarding comments on the
financial statements and related matters.  Please contact Greg
Belliston at (202) 824-5219 or me at (202) 942-1840 with any other
questions.

							Sincerely,

							Jeffrey P. Riedler
							Assistant Director

cc:	Jonathon J. Taylor, Esq.
	Nathan E. Seiler, Esq.
	Kendall, Koenig & Oelsner PC
	1675 Broadway, Suite 750
	Denver, CO 80202
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Antonio Milici, M.D., Ph.D.
GeneThera, Inc.
April 6, 2005
Page 1

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