SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
[LOGO]
[GENETHERA]

                                                                   June 7, 2005

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

Re:   GeneThera, Inc.
      Amendment No. 1 to Registration Statement on Form SB-2
      (the "Registration Statement")
      File  No. 333-123138

Dear Mr. Riedler,

      In response to the letter of the Staff of the Securities and Exchange
Commission, dated April 6, 2005, we have amended the Registration Statement
captioned above to further describe the expertise and qualifications of 0711005
B.C. Ltd. We have also identified the controlling person, Joseph Fernando, of
0711005 B.C. Ltd in the Selling Shareholders section on Page 38 and in the
Security Ownership of Certain Beneficial Owners and Management section on Page
33. For your reference, the description of the expertise and qualifications of
0711005 B.C. Ltd., which appears, among other places, in the Recent Developments
section on Pages 1-2 is as follows (new language in bold):

            In March 2005, we entered into a consulting agreement with 0711005
      B.C. Ltd (the "Marketing Consultant") pursuant to which the Marketing
      Consultant agreed to provide us with certain marketing and public
      relations services in exchange for the issuance of 1,375,000 shares of our
      common stock. These shares had a market value of approximately $1,430,000
      on the date of issuance, which our board determined to be a reasonable
      amount for the marketing and public relations services to be provided by
      the Marketing Consultant. The shares issued to the Marketing Consultant
      are offered for resale in this prospectus. 0711005 BC Ltd. Marketing Group
      is an organization that specializes in marketing and public relations for
      emerging growth publicly listed companies. 0711005 BC Ltd has designed a
      marketing campaign specific to GeneThera that will include, but not be
      limited to, the presentation of investment kits to thousands of inquiring
      investment professionals and investors making requests for information,
      attendance at trade shows throughout North America and Europe to generate
      additional investment leads and ongoing contact with the investment
      community, broker luncheons in major financial centers to present and
      personally introduce GeneThera management to the brokerage community,
      provide research writers direct access to the company management allowing
      them the opportunity for review of the company, and provide the company
      with an opportunity to communicate its story to investment professionals
      through the print and television media. 0711005 BC Ltd. Marketing Group
      has performed similar marketing campaigns for the last five years with
      similar publicly listed companies.

      The amended Registration Statement also includes our consolidated
financial statements as of and for the year ended December 31, 2004, which were
included as part of our 10-KSB/A filed on June 2, 2005.

<PAGE>

      For your convenience, we have included in the paper filing of this letter
one marked copy of the amended Registration Statement marked against the initial
Registration Statement filed on March 3, 2005 (other than the financial pages).

      Pursuant to Rule 461 under the Securities Act of 1933, as amended,
GeneThera, Inc. requests that the effective date of the Registration Statement
be accelerated so that the Registration Statement may become effective by 9:30
a.m. on the morning of June 10, 2005 or as soon thereafter as practicable.

     GeneThera acknowledges that:

      o     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;

      o     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

      o     The Company may not assert this action as defense in any proceeding
            initiated by the Commission or any person under the federal
            securities laws of the United States.

Sincerely,

/s/ Steven M. Grubner
Chief Financial Officer

                                       2
</TEXT>
</DOCUMENT>