SecProbe.io

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                               [IPIX LETTERHEAD]

United States
Securities and Exchange Commission
Washington D.C. 20549

Division of Corporate Finance
Mail Stop 4561

August 4, 2005

Re: Response to SEC letter dated July 12, 2005
       IPIX Corporation
       Form 10-K for the year ended December 31, 2004
       Filed March 31, 2005
       File No. 000-26363

QUESTION:
1. Please  confirm to us that you will revise your  disclosure in future filings
in response to comments 1 and 7 in our letter dated May 23, 2005.

RESPONSE:
In future  filings we will  revise our  disclosures  to address  both  comment 1
regarding  Liquidity and Capital  Resources  and comment 7 regarding  repurchase
rights of the Patent Agreement with AdMissions.

QUESTION:
2. We note from your response to comments 8 and  disclosure on page 15, that you
integrated  your  infomedia  and security  business  units in the 4th quarter of
2004.  However,  your  disclosures  in MD&A present these as distinct units with
different products, markets and business models. As such, please tell us how you
considered  paragraph  10 and 17 of  SFAS  131 for  purposes  of  defining  your
operating and reportable  segments.  In your response,  please also discuss what
measure of profit and loss is reviewed by the chief operating decision maker for
both of these units.

RESPONSE:
The  immersive  video  (formerly   security)  and  immersive   stills  (formerly
infomedia)  product lines are our two main product offerings but as disclosed in
the March 31, 2005 10-Q we offer both  products to our customers and market them
together and analyze the business  results with both products  integrated.  SFAS

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131  paragraph 10 states that the chief  operating  decision  maker  reviews the
results to make decisions about the business segment's  resources and assess its
performance. This does not occur separately for the two lines of products. There
is no financial information available for these product lines other than revenue
and cost of sales information by product line. In addition, in January 2005, the
general manager positions of the former segments were eliminated.  As such there
are no "segment managers" as defined in paragraph 14 of SFAS 131.

SFAS 131  paragraph 17 states that  business  segments can be aggregated if they
have similar  economic  characteristics.  The nature of the products is the same
with  immersive  video and stills  products.  One is a video camera and one is a
still camera but both capture  360(degree) images. The video and still lines are
comprised of finished  inventory and components  purchased from vendors so there
is no production  process.  The type and class of customer are integrating as we
market  and  sell  immersive  solutions  to  our  customers.   We  have  channel
distributors  and  resellers  for  both of our  product  lines.  As all of these
characteristics  can describe either product line,  Management  feels that these
are not distinct  business  units.  In future filings we will revise our MD&A to
include  these  changes  and make the  descriptions  of the  lines of  business,
customers and markets succinct to our current business practices.

QUESTION:
3. Based on your response to comment 10, it appears that these  indemnifications
are in the  scope  of  paragraph  3 (c) of Fin  45.  Please  advise  us how  you
concluded  that the fair value of both your  noncontingent  obligation  to stand
ready to perform and contingent  obligation under SFAS 5 is immaterial.  We wish
to remind that under  paragraph 9 of FIN 45 the  probability of payments will be
required under the guarantee  does not permit you from  initially  recognizing a
liability.  In your response,  please explain to us how you applied paragraphs 9
and 10 of FIN 45 in determining the fair value of the liability.

RESPONSE:
According to FASB Staff Position FIN45-1,  "Accounting for Intellectual Property
Infringement   Indemnifications   under   FASB   Interpretation   No.   45"  our
indemnifications  does  constitute a guarantee that is subject to the disclosure
requirements  but not the initial  recognition or measurement  provisions of FIN
45.  In  addition,   we  have   analyzed  the  estimated   liability   from  our
indemnifications  and deemed the amounts to be  immaterial  for  disclosure.  As
such,  in  future  filings  we will  keep  the  current  disclosure  and add the
following from paragraph 13 and 14 of FIN 45:
  a) Nature of any recourse provisions to allow us to recover from third parties
     any amounts paid under the guarantee.
  b) Our accounting policy and methodology used in determining its liability for
     product warranties.
  c) A tabular  reconciliation  of the changes in our aggregate product warranty
     liability for the reporting period (if any).
Under SFAS 5 loss  contingencies  arising under warranty  guarantees are accrued
when they are probably and reasonably estimated. The Company has deemed that the
intellectual  property  infringement  indemnification  contingent  liability  is

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immaterial  for accrual as we  performed  a  probability  analysis of  potential
outcomes for the  contingent  liability  based on past claims and cost  incurred
related to such obligation.

We acknowledge 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  proceedings
     initiated by the Commission or any person under the federal securities laws
     of the United States.

Regards,

/s/ Charles A. Crew
------------------------------

Charles A. Crew
Executive Vice President, CFO
IPIX Corporation

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