SecProbe.io

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Mail Stop 6010

September 16, 2005

Micheline Bouchard, President and Chief Executive Officer
ART Advanced Research Technologies, Inc.
2300 Alfred-Nobel Boulevard
Saint-Laurent, Quebec   H4S  2A4   Canada

Via U S Mail and FAX [(514) 832-0778 ]

	Re:	ART Advanced Research Technologies, Inc.
		Form 20-F for the fiscal year ended December 31, 2004
		Form 6-K for the fiscal 2005
		File No.  0-30214

Dear Ms. Bouchard:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures, and do not intend to expand our review to
other
portions of your documents. Where indicated, we think you should
revise your documents in response to these comments in all future
filings with the Commission.  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
information so we may better understand your disclosure.  After
reviewing this information, we may 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.

Ms. Micheline Bouchard
ART Advanced Research Technologies, Inc.
September 16, 2005
Page 2

Form 20-F for the fiscal year ended December 31, 2004

Item 5. Results of Operations, page 53

1. Please revise MD&A to provide more specific details of the
reasons
for each of the significant factors that contributed to
significant
variances in financial statement amounts each period. The current
discussion does not discuss all the specific factors that
contributed
to the significant increases in revenues, gross margins and
expenses
each period.

Financial Statements

General

2. Please revise to include financial statements for three years
as
required by Items 8 and 17 of Form 20-F.  We also reference the
requirement of Rule 3-06 of Regulation S-X that the filing of
financial statements covering a period of nine to 12 months shall
be
deemed to satisfy a requirement for filing financial statements
for a
period of one year.

Note 9(c) - Share Capital and Share Purchase Warrants, page 17

3. The amounts paid for the strategic alliances and agreements
that
are included in other expenses in the income statements appear to
relate to operations and should be reclassified to operating
expenses. Please revise.

Note 12 -  Related Part Transactions, page 23

4. Please tell us the nature of the clinical research fees and
what
is meant by the statement that these transactions were recorded at
their exchange value.  Please clarify the accounting treatment and
indicate whether the amounts were paid in cash.

Ms. Micheline Bouchard
ART Advanced Research Technologies, Inc.
September 16, 2005
Page 3

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  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 filing reviewed by the staff to
be
certain that the filing includes all information required under
the
Securities Exchange Act of 1934 and 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 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 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 filing or in response to
our comments on your filing.

      You may contact Jeanne Bennett at (202) 551-3606, or me at
(202) 551-3676, if you have questions regarding our comments.  In
our
absence you may contact Martin F. James, Senior Assistant Chief
Accountant at (202) 551-3671.
      Sincerely,

      Brian R. Cascio
      Accounting Branch Chief
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