SecProbe.io

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                                                                October 18, 2004

Mr. Jeffrey Riedler, Esq. Mail Stop 3-09
United States Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.D. 20548

Re:      GeneThera, Inc.
         Comment Letter
         File No. 333-118937

Dear Mr. Riedler,

Thank you for the comment letter sent by your department on October 7, 2004. We
have attempted to address all the comments in a comprehensive manner. We are
sending three bound "marked" copies of the amended filing and three "clean"
copies that we hope will facilitate your review. This letter will attempt to key
our responses to your comments. We will use the term "Completed" to acknowledge
our completion of the request outlined by the comment.

Form SB-2

General

1.    In your next amendment, please update the disclosure, including updated
      financial information, and in your Risk Factor section, as of a recent
      date practicable. Completed

2.    Please provide updated interim financial information in accordance with
      Item 310(g) of Regulation S-B. We have just closed our third quarter on
      September 30, 2004. We will file this 10QSB prior to November 11, 2004.
      Item 310 (g) speaks of a 135 day prior period, I believe our filed second
      quarter ending June 30, 2004 fits this timeframe?

3.    Although Form SB-2 does not contain a space to indicate that the
      securities are to be offered on a delayed or continuous basis pursuant to
      Rule 415 under the Securities Act of 1933, please revise to include this
      disclosure. Completed

4.    Please revise the third line where you disclose the number of shares of
      common stock to say "up to 4,249,236 shares of common stock." Completed

5.    Please provide the information requested by Item 501 (a)(9)(iv) of
      Regulation S-B. Completed

6.    Please revise the cover page to delete the last sentence of the first
      paragraph and the three bullet paragraphs that follow. This information is
      not required by Item 501. Consideration should be given to relocating this
      information to the selling security holder section. Completed

7.    Please expand the discussion to briefly identify your second subsidiary
      and the nature of its business. Completed

8.    Please reconcile the reference to GeneThera (Colorado) as a subsidiary
      with the discussion in the last sentence on page 23 under "Certain
      Relationships and Related Transactions" which suggests the acquisition has
      not yet been completed. Completed

9.    Please file the InvestLinc Securities and NVO Solutions agreements as
      exhibits. Completed

10.   We note your disclosure in the Recent Development sections that you are in
      default on notes payable in the amount of $44,517, including accrued
      interest. Please add a separate risk factor disclosing the risk and
      consequences of such default. In your discussion, please disclose the
      holders of such notes payables, and if you expect such parties to commence
      legal action. In the alternative, advise us as to why you do not believe a
      risk factor is necessary. Upon further review of our financial statements
      with our auditors, it has been determined that the Company is not in
      default on these notes. Our third quarter filing will reflect the reversal
      of these transactions.

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11.   Given that insiders of the Company own approximately 64% of the equity
      stock of GeneThera, please add a risk factor that discusses the risk and
      potential consequences to your market price of future sales of by these
      individuals. In your discussion, please include the number of your
      presently outstanding shares, the number that is freely tradable and the
      number that is subject to Rule 144. Completed

12.   Given the fluctuations in price that your shares have experienced in the
      last two years, please consider adding a quantified risk factor so that
      investors can appreciate the risk stemming from the volatility of your
      common stock. If you decide to add a risk factor discussing the volatility
      of your stock, please disclose the price range of your common stock during
      the most recent two fiscal years and interim period. Note that it is not
      necessary to replicate the table included on page 23 of your document
      under the subheading "Market for Common Equity and Related Stockholder
      Matters." Instead, you may disclose the high and low price during this
      period. In addition, please explain if any one particular factor has
      resulted or is anticipated in causing volatility in your stock price, if
      any. Completed

13.   Please include a risk factor that discusses your charter and bylaw
      provisions and how such provisions would prevent a change of control in
      management. In the alternative, advise us as to why you do not believe a
      risk factor is necessary. Completed

14.   Many of your subheadings currently either merely state a fact about your
      business, such as "We do not have a sales, marketing, or distribution
      capabilities and no experience in those areas," and "Many of our
      competitors and potential competitors have resources superior to ours," or
      describe an event that may occur in the future, such as "Our technology
      may conflict with patents held by others." Succinctly state in your
      subheadings the risks that result from the facts or uncertainties.
      Completed

15.   Please revise your heading and accompanying discussion to include
      disclosure concerning the "going concern" opinion set forth in your
      accountants' consent. Completed

16.   Please revise the subheading to include the risk in the event additional
      funding is not obtained. Completed

17.   Please expand the discussion to indicate the additional funding required
      and when these funds are needed. In this regard, we note the discussion
      under "Liquidity and capital resources" on page 10. Completed

18.   Please briefly describe whether you have any applications before the USDA
      or other approvals for your key products, the stage of the approvals of
      your products in process, and the amount you have spent on research and
      development. You should provide more detailed disclosure in the "Business"
      section of your document. Completed

19.   Please consider discussing your competitive position vis-a-vis other
      companies that are in your specific industry. If available, please
      identify your primary competitors. Completed

20.   Please identify the key personnel with whom you maintain employment
      agreements. We note your description of two employment agreements in your
      document. Completed

21.   Please revise the subheading of this risk factor to clearly identify the
      risk and potential consequences. At present, this risk factor heading does
      not appear to adequately describe the risk of investors. Your reader
      should be able to understand the nature of the risk to the investment by
      reading the caption to your discussion. Please revise your subheading to
      clearly identify a risk. Completed

22.   Please disclose the dilution shareholders would experience if shares of
      your common stock were sold at a price as of a recent date. Please provide
      similar disclosure in the section of your document entitled "Dilution" on
      page 8. The price of $1.50 is a price as of a recent date.

23.   Please expand the discussion to clarify how you determined the
      calculations used in the second paragraph. If the risk is to potential
      purchasers of the shares that are the subject of the current registration
      statement, at what price are the shares to be sold to potential
      purchasers? Completed

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24.   Please revise the discussion in the prospectus where appropriate to
      discuss in greater detail the agreement with InvestLinc. Completed

25.   Revise this risk factor to express the risk to investors, for example,
      that investors will only see a return on their investment if the value of
      the shares appreciates. Completed

26.   Please address the topics required by Item 303 of Regulation S-B,
      including expected significant infrastructure changes during this period
      (e.g. increase/decrease in number of employees and plant start up) and a
      discussion of off-balance sheet arrangements that are reasonably likely to
      have a current or future effect on the Company's financial condition,
      revenues, results of operations, liquidity, capital expenditures that is
      material to investors or state that none exist. Completed

27.   Please expand the discussion in the prospectus to address the specifics of
      your business plan referred to on page 10. Completed

28.   Please include a table of contractual obligations. Completed

29.   We note your disclosure that you experienced a decline in gross profits
      from the same period last year "due to the research and development state
      the company is in at the present time." Please expand your description to
      specifically disclose what state the company is at present. For example,
      have you halted testing certain proposed products or services? How was the
      state of your company different in this period as compared to the same
      period last year? Completed

30.   In addition, please clarify the product and/or services for which you
      received revenue in the 2003 period. Completed

31.   Please explain the reasons for the decrease in personnel (salaries)
      expenses. Completed

32.   We note you have filed several agreements related to equity line credit
      agreements in your registration statement. Please describe the material
      terms of such agreements in this section. This agreement was cancelled
      prior to ever being finalized. Should it be removed from future filings as
      an exhibit?

33.   Please identify the investors to whom you issued convertible promissory
      notes. Completed

34.   Please disclose the expiration date for each of the notes. In addition,
      indicate if you are currently in default on any of these notes. In this
      regard, we note your disclosure in the Recent Development sections that
      you are currently in default on notes payable. Completed

35.   Please explain the discrepancies in the conversions that have occurred.
      For example, the May 16, 2003 note in the principle amount of $60,000 was
      convertible at a rate of $0.25 per share and was converted into 240,000
      shares of common stock. However, the notes issued between May 17, 2003 and
      September 19, 2003 in the principle amount of $215,000 were convertible
      into common stock at a rate of $0.50 per share and the notes were
      converted into 436,926 shares, a number that exceeds the conversion ratio.
      Please advice or revise. The $215,000 was converted along with interest
      accrued of $3,463 into shares at $0.50 shares by election of the note
      holder.

36.   Please expand the discussion to clarify whether the consideration received
      in each note sale equaled the principal amount of the note issued. In this
      regard, we note the reference to the January 12, 2003 note sale in the
      principal amount of $120,000 and the fact only $36,900 was raised. In
      addition, we note the conversion ratio was $0.50 per share, yet the note
      was converted into 80,000 shares. Please advice or revise. Completed

37.   Please explain what the "Molecular Biology Potential Agreement Structure"
      is. In addition, please briefly describe what each of the stages your list
      entails. Completed

38.   Please provide supplemental support for the statement that your senior
      scientists have more than 100 years of research and development
      experience. In addition, please provide the information requested by Item
      401(b) of Regulation SB. We modified the 100 years to 50 years and
      attached curriculum vitae of the three scientists that make up these years
      of experience.

39.   Please expand the discussion to explain the absence of any revenues in
      2004. If the products and services referred to in this section were
      available in 2003 and revenues were derived from such products and
      services, why were there no similar revenues in 2004? Completed

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40.   Please expand the discussions to identify the vaccines you have developed
      using the platform and the amount of time required to develop each of
      these vaccines. We may have additional comment. Completed

41.   Please expand the discussion to clarify whether the GEA system is intended
      solely for your use or for sale to other laboratories. If the system can
      be sold to other laboratories, please indicate the number of units you
      have sold to date, indicating when such sales began. Completed

42.   Please expand the discussion to provide a balanced presentation including,
      any disadvantages to the GEA system and any advantages to other systems or
      methods available to test for veterinary diseases or food contamination.
      In this regard, we note your discussion concerning the methods use by
      "most labs" which phrase suggests alternatives are available. Completed

43.   Please expand the discussion to indicate when the GEA system was developed
      and the extent of its utilization to date. Completed

44.   Please expand the discussion to indicate when the system was developed,
      when sales began, and the extent of sales to date. In this regard, we note
      your intent to begin a marketing campaign to achieve higher volume sales.
      Completed

45.   Please note that Item 101 of Regulation S-B requires the description of a
      small business issuer's business during the last three years. Please
      revise your Business section to comply with this requirement. Completed

46.   Please provide disclosure of the background of the reverse acquisition by
      and between you and Hand Brand Distribution as well as the reverse
      acquisition of GeneThera. For example, discuss: Completed

47.   For each product/service that is still in development, please disclose the
      status of any regulatory review or clinical trials; the estimated amounts
      required to complete development, testing and regulatory approval process;
      and when you anticipate commencement of the marketing efforts. Completed

48.   Please expand the discussion to include the development of emerging
      technologies or products that may compete with you and the current stage
      of development of these technologies or products. Completed

49.   Please discuss the status of your employee relations. Completed 50. Please
      file your lease agreement as an exhibit. Completed

51.   Please expand the discussion concerning each proceeding and counterclaim
      to include a description of the facts underlying the proceeding. For
      example, what is the specific nature of the fraud, breach of contract, and
      violation of state consumer protection law alleged in the counterclaim
      described in the first paragraph. The lawsuit referenced in the SB-2 has
      been settled as of October 13,2004. We eliminated it from the filing.

52.   Please disclose when you held your last annual meeting, and when you plan
      to hold your next annual meeting. Completed

53.   Please note that Item 401(a)(4) of Regulation S-B requires a brief
      description of the business experience of your officers and directors
      during each of the last five years. Many of your offi