SecProbe.io

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      May 23, 2005

Mail Stop 4591

VIA U.S. MAIL and FAX (703) 674-4104

Charles A. Crew
Chief Financial Officer
12120 Sunset Hills Road, Suite 410
Reston, Virginia 20190

Re:	IPIX Corporation
	Form 10-K for the year ended December 31, 2004
	Form 10-Q for the period ended March 31, 2005
	File No. 000-26363

Dear Mr. Crew:

      We have reviewed your above referenced filings and have the
following comments.  We have limited our review to selected
financial
data, management`s discussion and analysis and the financial
statements and will make no further review of your documents.  As
such, all persons who are responsible for the adequacy and
accuracy
of the disclosure are urged to be certain that they have included
all
information required pursuant to the Securities Exchange Act of
1934.

      Where indicated, we think you should revise your documents
in
response to these comments in future filings.  If you disagree, we
will consider your explanation as to why our comment is
inapplicable
or a revision is unnecessary.  Please be as detailed as necessary
in
your explanation.  In some of our comments, we may ask you to
provide
us with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K filed 3/30/05

Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations, page 15

Liquidity and Capital Resources, page 25

Summary of Consolidated Cash Flow Data, page 26

1. Please revise your discussion of cash flow from operating
activities to discuss the underlying drivers impacting the changes
in
working capital. Simply identifying that components of working
capital changed does not provide a sufficient basis to analyze
your
cash flow from operating activities.  Refer to the Interpretive
Guidance in SEC Release 33-8350.

Consolidated Statements of Operations, page F-4
2. We noted in your MD&A and in Footnote 2, you have product,
service
and royalty revenue, however, you only present product revenue on
the
face of your financials. Please confirm service and royalty
revenue
are less than 10% of the total revenues in accordance with Rule 5-
03
(b) of Regulation S-X.

Note 2. Summary of Significant Accounting Policies, page F-8

Revenue Recognition, page F-9

3. We noted your product revenue is recognized upon shipment or
delivery.  Please clarify what factors determine whether a
product`s
revenue will be recognized at shipment or delivery.

4. We noted that when multiple elements exist in an arrangement,
the
arrangement fee is allocated to the different elements based upon
verifiable objective evidence. Please supplementally explain the
types of arrangements that fall within this category, especially
the
nature of professional services provided.  In addition, please
tell
us which items have verifiable objective evidence and explain the
nature of that evidence.

Note 3. Going Concern Considerations, page F-12

5. We note that the company believes it can generate sufficient
cash
flow to fund its operations for at least 12 months; however, it
appears you are also planning to make significant investments in
the
sale and marketing of new products for the security market, which
may
consume available cash reserves.  We also note that your 2004 cash
used in operating activities exceeds your cash reserves.  Please
expand your discussion in future filings and supplementally to
explain how you will manage your product expansion while also
maintaining sufficient cash flow.

Note 4. Discontinued Operations, page F-12

6. We noted you entered into a Patent Purchase, License and
Repurchase Agreement with AdMission Corporation.  Please tell us
how
you accounted for the transfer of certain patents relating to the
AdMission Business, while the licenses for the patents remained
with
IPIX.  In addition, please tell us how you will account for the
license fee and whether you will recognize an asset as a result of
the repurchase right.

7. Please tell us what type of event would trigger repurchase
rights
by IPIX.    In addition, please tell us and disclose in future
filings when the Patents covered under the Patent Agreement
expire.

Note 11. Segment Information, page F-19

8. We noted your reconciliation by segment to the total company
did
not include a reconciliation to consolidated net income.  Please
expand your segment information disclosure to include a complete
reconciliation in accordance with paragraph 32 of FAS 131.

Note 2. Summary of Significant Accounting Policies, page F-8

Inventory, page F-9

9. It does not appear that you considered excess inventories in
analyzing your inventory for impairment.  In light of your
significant increase in inventory from the prior year, please
advise
us and disclose in future filings how you have considered whether
your inventory is excessive and the impact it could have on the
valuation.  Refer to Chapter 4 of ARB 43.

Note 12. Commitments and Contingencies, page F-19

Indemnifications, page F-20

10. Please advise us how you have considered the guidance in FIN
45
in accounting for these indemnification provisions.

Item 9A. Controls and Procedures

11. In future filings, please refer to the definition of
disclosure
controls and procedures defined in Exchange Act Rules 13a-15(e)
and
15d-15(e) as required by Item 307 of Regulation S-K.

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
cover letter that keys your responses to our comments and provides
any requested supplemental information.  Detailed cover letters
greatly facilitate our review.  Please file your cover letter on
EDGAR.  Please understand that we may have additional comments
after
reviewing your amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

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

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* 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.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.

      You may contact Monica Brame, Staff Accountant, at (202)
551-
3473 or the undersigned at (202) 551-3403 if you have questions.

						Sincerely,

Steven Jacobs
Branch Chief Accountant
IPIX Corporation
May 23, 2005
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