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[LOGO OF GENETHERA]

                                                                   July 26, 2005

Mr. Joseph J. Roesler Mail Stop 3-09
United States Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20548

Re:   GeneThera, Inc.
      Item 4.01
      Filed July 15, 2005
      File No. 000-27237

Dear Mr. Roesler,

      Thank you for the  comment  letter  sent on July 21,  2005.  Following  is
      Genethera's response to your comment

Item 4.01 Form 8-K filed July 15, 2005

1.    We note that your accountants have changed their name to Kantor, Geisler &
      Associates,  LLC. It does not appear,  however,  that the accounting  firm
      Kantor,  Geisler &  Associates,  LLC is listed as a registered  accounting
      firm with the PCAOB.  There is an accounting firm called Kantor,  Sewell &
      Oppenheimer  PA  registered  with the PCAOB,  which appears to be the same
      accounting firm as Kantor, Geisler & Associates. Please confirm to us that
      your accounting firm is registered with the PCAOB.

      We have been advised by our accounting firm that they are currently in the
      process of registering the new LLC, Kantor, Geisler & Associates, LLC with
      the PCAOB.  Kantor,  Sewell & Oppenheimer  was the  predecessor  entity to
      Kantor, Geisler & Associates, LLC.

The company also acknowledges that:

      o     The company is  responsible  for the  adequacy  and  accuracy of the
            disclosure in the filings;

      o     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

      o     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.

Please do not  hesitate  to contact me with any  further  questions  or comments
regarding  this  response  or if you'd  like  follow-up  information  once their
registration with the PCAOB is acknowledged.

                                                        Sincerely,

                                                        /s/ Steven M. Grubner
                                                        -----------------------
                                                        Steven M. Grubner
                                                        Chief Financial Officer

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