SecProbe.io

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April 8, 2005

By Facsimile and U.S. Mail

Kenneth R. Myers, Esq.
Siemens Corporation
153 East 53rd Street
New York, New York 10022

	Re:	CTI Molecular Imaging, Inc.
		Schedule TO-C filed March 18, 2005
		Filed by Siemens Aktiengesellschaft

		Schedule TO-T filed April 1, 2005
		Filed by MI Merger Co., Siemens Medical Solutions USA,
		Inc. and Siemens Aktiengesellschaft

Dear Mr. Myers:

	We have the following comments on the above-referenced
filings.

Schedule TO-C

1. We note the statement that neither Siemens nor CTI are under an
"obligation to (and each expressly disclaims any such obligation
to) update or alter its forward-looking statements, whether as a
result of new information, future events or otherwise."  This
disclaimer is inconsistent with the requirements of General Instruction F
of Schedule TO and your obligations under Rule 14d-6(c) to amend the
Schedule to reflect a material change in the information
previously disclosed.  Please confirm that the bidders will avoid using
this statement in all future communications.

Schedule TO-T

Fee Table

2. Please reconcile your statement in the fee table that 2,148,545
shares of common stock are subject to vested options, warrants and
deferred stock units shares and the disclosure on page 3 of the
Offer to Purchase that as of March 17, 2005 3,807,431 shares were
reserved for issuance pursuant to outstanding stock options, stock
units, warrants and other rights.  For example, state whether or not
this discrepancy arises because some securities are immediately
exercisable or convertible whereas others are not yet vested or
are restricted.

Offer to Purchase

Acceptance for Payment and Payment of Shares - Page 5

3. Please revise the language that states that you will return
share certificates evidencing unpurchased shares "as promptly as
practicable" to state that you will make such returns "promptly"
as required by Rule 14e-1(c).

Certain Information Concerning the Company - Page 11

4. We note that you have included a "summary" of financial
projections provided by CTI Molecular to you.  Please provide us
with a copy of the complete financial projections and tell us your
basis for not disclosing the information in its entirety.

5. We note the statement that none of Siemens Medical Solutions,
MI Merger or their respective affiliates intend to update the
financial projections to reflect the occurrence of future events.
This disclaimer is inconsistent with the requirements of General
Instruction F of Schedule TO and your obligations under Rule 14d-
6(c) to amend the Schedule to reflect a material change in the
information previously disclosed.  Please confirm that the bidders
will avoid this using this statement in all future communications.

6. We note the disclosure that indicates neither Parent nor
Purchaser bears any responsibility for the accuracy and completeness
of the projections.  While the staff does not object to inclusion of
qualifying language with respect to such projections, it remains
inappropriate to disclaim responsibility for this information.
Please revise.

Exhibit (a)(7)

7. We note that your summary advertisement does not include a
statement regarding the federal income tax consequences of the
tender offer, as required by Rule 14d-6(d)(2) and Item 1004(a)(1)(xii)
of Regulation M-A.  Please advise us why this required disclosure was
not included here or in the summary section of the tender offer
that was disseminated to security holders.

Closing Information

      Please amend your filing promptly to comply with our
comments. If you do not agree with a comment, please tell us why in
your response.  If the information you provide in response to our
comments materially changes the information that you have already
provided to unit holders, disseminate the revised materials in a
manner reasonably calculated to inform them of the new information.
Depending upon your response to these comments, a supplement may
need to be sent to unit holders.

      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 bidder is in possession of all
facts relating to its disclosure, it is responsible for the accuracy
and adequacy of the disclosures it has made.

	In connection with responding to our comments, please
provide, in writing, a statement from the bidder(s) acknowledging that:

* the bidder(s) is (are) responsible for the adequacy and accuracy
of the disclosure in the filings;

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

* the bidder(s) 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.

      Please direct any questions to me at (202) 942-2962 or, in
my absence, to Nicholas Panos, Special Counsel, at (202) 942-2920.
You may also contact me via facsimile at (202) 942-9585.  Please send
all correspondence to us at the following ZIP code: 20549-0306.

					Sincerely,

					Daniel F. Duchovny
					Attorney-Advisor
					Office of Mergers & Acquisitions

cc: Stephen M. Besen, Esq. (via fax: (212) 848-7179)

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