SecProbe.io

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                                 BRAUN & COMPANY
                           ---------------------------
                           BARRISTERS AND SOLICITORS**

Thomas A. Braun, B.A., LL.B., LL. M.*

May 23, 2005

By Fax

Jay Webb
Reviewing Accountant
Division of Corporate Finance
Securities and Exchange Commission
Washington, D.C. 20549

RE:      MIV THERAPEUTICS, INC.
         FILE NUMBER 000-30453
         FORM 10-KSB FOR THE FISCAL YEAR ENDED MAY 31, 2004
         FORM 10-QSB FOR THE QUARTERLY PERIOD ENDED AUGUST 31, 2004
         FORM 10-QSB FOR THE QUARTERLY PERIOD ENDED NOVEMBER 30, 2004

Dear Mr. Webb:

Thank you for your letter dated April 20, 2005. I am responding on behalf of my
client, MIV Therapeutics, Inc. We have reviewed your suggestions and taken the
time to seriously consider your remarks. Pursuant to your comments we have
amended certain information on the Forms listed above and will do our best to
ensure that future filings include the information you suggest.

MIV Therapeutics, Inc. acknowledges that, as the registrant, it is responsible
for the adequacy and accuracy of the disclosures in its filings, that staff
comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing, and that it
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.

Below, we stated our responses to your comments. We have also attached marked up
copies of the sections of our filings that we will file in amended Forms on the
same day that we file this response.

                                       1

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Form 10-KSB for the fiscal year ended: May 31, 2004
---------------------------------------------------

1. We will file a revised form 10-KSB for the fiscal year ended: May 31, 2004 to
include information relating to controls and procedures required by Item 8A of
Form 10-KSB

Form 10-KSB for the fiscal year ended: May 31, 2004
---------------------------------------------------

Financial Statements - Page F-1

2. The Financial Statements have been revised to present audited financial
information for the cumulative data presented.

3. The auditor's report has been revised by Morgan & Company to reference "the
standards of the Public Company Accounting Oversight Board (United Sates)".

Consolidated Statement of Operations - Page F-9

4. The $503,428 of "Impairment of Intangible Asset" has been reclassified as an
operating expense under "Purchased In-Process Research and Development". Please
see the revised financial statements enclosed.

Recapitalization - Page F-11

5. The transaction is accounted for by the purchase method in accordance with
FASB No. 141 "Business Combinations". In accordance with EITF 99-12
"Determination of the measurement Date for the Market Price of Acquirer
Securities Issued in a Purchase Business Combination", the share price used to
determine the purchase price for accounting purposes was based on the average
closing market price of the Company's common stock for the 7 trading days, which
includes the 3 trading days before and after the acquisition was agreed and the
shares were exchanged on - June 18, 2003.

                                       2

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Form 10-QSB for the quarterly period ended August 31, 2004 and Form 10-QSB for
------------------------------------------------------------------------------
the quarterly period ended November 30, 2004
--------------------------------------------

6. We will file revised form 10-QSBs for the quarterly periods ended August 31,
2004 and November 30, 2004 to include amended certifications that will be in the
exact form prescribed in Item 601 (b)(31) of Regulation S-B.

7. We will file revised form 10-QSBs for the quarterly periods ended August 31,
2004 and November 30, 2004 to amend the disclosure relating to Controls and
Procedures in the manner you suggest.

8. We will file revised form 10-QSBs for the quarterly periods ended August 31,
2004 and November 30, 2004 to amend the disclosure relating to Controls and
Procedures in the manner you suggest.

Yours very truly,

BRAUN & COMPANY per:

Thomas A. Braun
Encl.

cc: Pat McGowan
     CFO
     MIV Therapeutics, Inc.
     Fax: (604) 301-9546

                                       3

<PAGE>

               MIV THERAPEUTICS INC.
               (A development stage company)

               Consolidated Financial Statements

               May 31, 2004

               INDEX
               -----

               Report of Independent Registered Public Accounting Firm       F-2
               Consolidated Balance Sheets                                   F-4
               Consolidated Statements of Stockholders' Equity               F-5
               Consolidated Statements of Operations                         F-9
               Consolidated Statements of Cash Flows                        F-10
               Notes to Consolidated Financial Statements                   F-11

                                      F-1

<PAGE>

                         [MORGAN & COMPANY LETTERHEAD]

             REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Board of Directors and Stockholders of
MIV Therapeutics Inc.
(A Development Stage Company)

We have audited the consolidated balance sheet of MIV Therapeutics Inc. (a
development stage company) as at May 31, 2003 and 2002, and the related
consolidated statements of operations, cash flows, and stockholders' equity for
the years ended May 31, 2003 and 2002, and the cumulative data from January 20,
1999 (date of inception) to May 31, 2003. These financial statements are the
responsibility of the Company's management. Our responsibility is to express an
opinion on these financial statements based on our audits. The Company's
financial statements for the period from January 20, 1999 (date of inception) to
May 31, 2001 were audited by other auditors whose report, dated November 13,
2001, expressed an unqualified opinion, has been furnished to us. Our opinion,
in so far as it relates to the amounts included for cumulative data from January
20, 1999 (date of inception) to May 31, 2001, is based solely on the report of
the other auditors.

We conducted our audits in accordance with the standards of the Public Company
Accounting Oversight Board (United States). Those standards require that we plan
and perform an audit to obtain reasonable assurance whether the financial
statements are free of material misstatement. An audit includes examining, on a
test basis, evidence supporting the amounts and disclosures in the financial
statements. An audit also includes assessing the accounting principles used and
significant estimates made by management, as well as evaluating the overall
financial statement presentation. We believe that our audits provide a
reasonable basis for our opinion.

In our opinion, these consolidated financial statements present fairly, in all
material respects, the financial position of MIV Therapeutics Inc. as of May 31,
2003 and 2002, and the results of their operations and its cash flows for the
years ended May 31, 2003 and 2002, and the cumulative data from January 20, 1999
(date of inception) to May 31, 2003, in conformity with accounting principles
generally accepted in the United States of America.

The accompanying consolidated financial statements have been prepared assuming
that MIV Therapeutics Inc. will continue as a going concern. As discussed in
Note 2 to the consolidated financial statements, MIV Therapeutics Inc. has
suffered losses from operations and has a working capital deficiency that raises
substantial doubt about its ability to continue as a going concern. Management's
plans in regard to these matters are also described in Note 2. The consolidated
financial statements do not include any adjustments that might result from the
outcome of this uncertainty.

Vancouver, Canada                                             "Morgan & Company"

July 29, 2003                                              Chartered Accountants

                                      F-2

<PAGE>

MOORE STEPHENS ELLIS FOSTER LTD.
CHARTERED ACCOUNTANTS

1650 West 1st Avenue
Vancouver, BC  Canada   V6J 1G1
Telephone:  (604) 734-1112  Facsimile: (604) 714-5916
Website:  www.ellisfoster.com

--------------------------------------------------------------------------------

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

TO THE BOARD OF DIRECTORS AND STOCKHOLDERS OF

MIV THERAPEUTICS INC.
(A development stage company)

We have audited the consolidated balance sheet of MIV THERAPEUTICS INC. (a
development stage company) ("the Company") as at May 31, 2004 and the related
consolidated statements of stockholders' equity, operations and cash flows for
the year ended May 31, 2004. These financial statements are the responsibility
of the Company's management. Our responsibility is to express an opinion on
these financial statements based on our audit. We did not audit the cumulative
data from January 20, 1999 (inception) to May 31, 2003 in the statements of
stockholders' equity, operations and cash flows, which were audited by other
auditors whose report, dated July 29, 2003, which expressed an unqualified
opinion, has been furnished to us. Our opinion, insofar as it relates to the
amounts included for cumulative data from January 20, 1999 (inception) to May
31, 2003, is based solely on the report of the other auditors.

We conducted our audit in accordance with standards of the Public Company
Accounting Oversight Board (United States). Those standards require that we plan
and perform an audit to obtain reasonable assurance whether the financial
statements are free of material misstatement. An audit includes examining, on a
test basis, evidence supporting the amounts and disclosures in the financial
statements. An audit also includes assessing the accounting principles used and
significant estimates made by management, as well as evaluating the overall
financial statement presentation. We believe that our audit provide a reasonable
basis for our opinion.

In our opinion, these financial statements present fairly, in all material
respects, the financial position of the Company as at May 31, 2004 and the
results of its operations and its cash flows for the year then ended in
conformity with generally accepted accounting principles in the United States of
America.

The accompanying financial statements have been prepared assuming that the
Company will continue as a going concern. As discussed in Note 1 to the
financial statements, the Company is a development stage company since inception
on January 20, 1999 and has incurred significant recurring net losses since then
resulting in a substantial accumulated deficit, which raise substantial doubt
about its ability to continue as a going concern. The Company is devoting
substantially all of its present efforts in establishing its business.
Management's plans regarding the matters that raise substantial doubt about the
Company's ability to continue as a going concern are also disclosed in Note 2 to
the financial statements. The ability to meet its future financing requirements
and the success of future operations cannot be determined at this time. These
financial statements do not include any adjustments that might result from the
outcome of this uncertainty.

Vancouver, Canada                             "MOORE STEPHENS ELLIS FOSTER LTD."
July 7, 2004                                         Chartered Accountants

--------------------------------------------------------------------------------
MSAN INDEPENDENTLY OWNED AND OPERATED MEMBER OF MOORE STEPHENS NORTH AMERICA,
INC. MEMBERS IN PRINCIPAL CITIES THROUGHOUT NORTH AMERICA. MOORE STEPHENS NORTH
AMERICA, INC. IS A MEMBER OF MOORE STEPHENS INTERNATIONAL LIMITED, MEMBERS IN
PRINCIPAL CITIES THROUGHOUT THE WORLD.

                                      F-3

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<TABLE>
MIV THERAPEUTICS INC.
(A development stage company)

<CAPTION>
Consolidated Balance Sheets
May 31, 2004 and 2003
(EXPRESSED IN U.S. DOLLARS)
-----------------------------------------------------------------------------------------------
                                                                      2004            2003
-----------------------------------------------------------------------------------------------

<S>                                                               <C>             <C>
ASSETS

CURRENT ASSETS
  Cash and cash equivalents                                       $  2,034,530    $     11,614
  Other receivable                                                      13,336         165,485
  Prepaid expenses and deposits                                        254,659          46,819
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TOTAL CURRENT ASSETS                                                 2,302,525         223,918

INVESTMENT, at cost (Note 4)                                                --          50,000

PROPERTY AND EQUIPMENT, net (Note 7)                                   177,549         312,179
-----------------------------------------------------------------------------------------------

TOTAL ASSETS                                                      $  2,480,074    $    586,097
===============================================================================================

LIABILITIES AND STOCKHOLDERS' EQUITY

LIABILITIES

CURRENT LIABILITIES
  Accounts payable                                                $    170,871    $    448,959
  Due to related parties (Note 9)                                       13,585         136,983
-----------------------------------------------------------------------------------------------

TOTAL CURRENT LIABILITIES                                              184,456         585,942

LOAN PAYABLE (Note 5)                                                       --         500,000
-----------------------------------------------------------------------------------------------

TOTAL LIABILITIES                                                      184,456       1,085,942
-----------------------------------------------------------------------------------------------

STOCKHOLDERS' EQUITY

COMMON STOCK (Note 8)
  Authorized:
         80,000,000 common shares with a par value of $0.001
         20,000,000 preferred shares with a par value of $0.001
  Issued and outstanding:
         40,092,993 common shares at May 31, 2004 and
         24,577,047 common shares at May 31, 2003                       40,093          24,577

ADDITIONAL PAID-IN CAPITAL                                          15,040,147       9,403,308

WARRANTS                                                             2,992,095       2,093,760

DEFERRED COMPENSATION                                                 (190,375)        (48,649)

COMMON STOCK ISSUABLE                                                       --          31,244

DEFICIT ACCUMULATED DURING THE DEVELOPMENT STAGE                   (15,424,227)    (11,952,336)

ACCUMULATED OTHER COMPREHENSIVE INCOME                                (162,115)        (51,749)
-----------------------------------------------------------------------------------------------

TOTAL STOCKHOLDERS' EQUITY (DEFICIENCY)                              2,295,618        (499,845)
-----------------------------------------------------------------------------------------------

TOTAL LIABILITIES AND STOCKHOLDERS' EQUITY                        $  2,480,074    $    586,097
===============================================================================================

THE ACCOMPANYING NOTES ARE AN INTEGRAL PART OF THESE FINANCIAL STATEMENTS.
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