SecProbe.io

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                           Bullivant|Houser|Bailey PC
                           1331 Garden Hwy., Suite 300
                              Sacramento, CA 95833
                              Tel No. 916-442-0400

                                                              November 3, 2005

VIA EDGAR

Jay Webb
Reviewing Accountant
Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 6010
100 F Street, N.E.
Washington, D.C. 20549

         Re:      MIV Therapeutics, Inc.
                  Form 10-KSB for fiscal year ended May 31, 2004.
                  Form 10-QSB for fiscal quarter ended February 28, 2005.

                  SEC 34 Act File No.: 000-30453

Dear Mr. Webb:

         On behalf of our client, this letter will set forth MIV Therapeutics'
(the "Company's") responses to the Staff's comment letter dated July 21, 2005 in
connection with the above-referenced filings. Our responses to the comments are
set forth in the order in which each comment appears in the Staff's letter.

1. The Company is filing amendment no. 3 to its Form 10-KSB for the year ended
May 31, 2004 to include a revised auditors' report to its financial statements
under Item 7. In particular, the report of Morgan & Company has been revised to
delete reference to another auditor's report. Morgan & Company has audited the
Company's accumulated data for the period since inception to the year of their
replacement. Therefore, reference to prior auditor's report is no longer
necessary.

         Further, the Company, for reasons in addition to the Staff's comment
number 1, has amended its Annual Reports on Forms 10-KSB for the years ended May
31, 2003, and 2005 which are being filed concurrent with this letter.

2. Through its wholly-owned subsidiary, the Company is the owner of a patent
entitled "Endovascular device for entrapment of particulate matter and method
for use." The Company believes that it can develop the application of this
patent into a marketable product. The Company and Sagax began negotiating the
purchase of this patent during the latter part of 2004. At the time of the
negotiations, the Company and Sagax were unaffiliated. Because Sagax needed
money to develop the patent, prior to the acquisition the Company loaned money
to Sagax for research and development. These loans totaling $198,400 in the
aggregate were evidenced by promissory notes made by Sagax in favor of the

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Company. Prior to the acquisition, Sagax had no employees and sporadically hired
consultants related to the development of the patent. Both the Company and Sagax
had further negotiations culminating to the entering of an Acquisition Agreement
dated March 14, 2005. Under the Acquisition Agreement, the Company acquired all
the outstanding shares of Sagax, Inc., a Delaware corporation. As previously
mentioned, Sagax's sole asset consisted of a patent in the United States and
related patents in other countries. Since its inception until entering into the
Acquisition Agreement, Sagax generated no revenues, had no employees, although
it engaged one consultant, had limited separate physical facilities, had no
market distribution system, had no sales force, had no customers, and had no
operating rights. The Company acquired Sagax to obtain ownership of the patent
and to further develop and potentially place it into a commercially viable
product. Subsequent to entering into the Acquisition Agreement, the Company is
maintaining a separate research and development facility and hired seven persons
acting as employees or consultants solely to develop the patent. The Company
does not believe that acquiring all of the shares of Sagax whose sole asset is a
patent is acquiring a "business" within the meaning of Rule 11(d) of Regulation
S-X.

         Further, even if it is determined that the Company may be acquiring a
business within the meaning of Section 11(d) of Regulation S-X, the Company does
not believe that Sagax is a significant subsidiary as defined in Rule 1-02(w)
and therefore no financial statements are required pursuant to Rule
3-05(b)(2)(i) of Regulation S-X. Under the terms of the Acquisition Agreement,
the Company agreed to acquire all of the outstanding Sagax's shares of common
stock for 4,200,000 shares of the Company common stock subject to certain
conditions. Prior to the acquisition, Sagax had no assets, and no revenues. As
of May 31, 2004, the Company had total assets of $2,480,074. Total advances made
by the Company to Sagax prior to the acquisition were $198,400. Clearly, Sagax
does not meet the definition of significant subsidiary (using both the 10% or
20% factors) since the total advances made by the Company to Sagax were less
than 10% of the Company's total assets. For the above stated reasons, no
financial statements or pro forma financial information regarding Sagax is
required.

         In addition, the Company is filing amendment number 3 to its
preliminary proxy statement. The Company has revised proposal number 2 to
increase the number of authorized shares of common stock to 120 million. This
increase in authorized shares of common stock will allow the Company to meet its
obligations to holders owning outstanding options or warrants and to seek
additional financing for its operations and for pre-clinical and clinical
trials. However, the Company, at this time, is not seeking an increase in
authorized shares of common stock to complete its proposed acquisition of
Sahajanand Medical Technologies, Inc. Further, the Company has no agreements,
understandings or arrangements to issue additional shares of common stock for
future financings.

         This will also confirm with the staff that the Company acknowledges
that the Company is responsible for the adequacy and accuracy of the disclosure
of the filing; 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 the Company may not assert staff comment as a defense in any
proceeding initiated by the Commission or any person under the federal
securities law of the United States.

         We believe that that the foregoing and the amendment made to the above
referenced reports address the Staff's comments. Should you have any further
questions, please do not hesitate to contact me.

                                                  Sincerely,

                                                  /s/ Daniel Eng
                                                  -------------------
                                                  Daniel Eng

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