SecProbe.io

October 14, 2010

Theodore D. Zucconi, Ph.D.  Chief Executive Officer and President  Pro-Pharmaceuticals, Inc.  7 Wells Avenue
Newton, Massachusetts 02459

Re: Pro-Pharmaceuticals, Inc.
  Registration Statement on Form S-1
Filed September 17, 2010
  File No. 333-169463

Dear Dr. Zucconi:
 We have reviewed your October 5, 2010 re sponse to our September 27, 2010 comment
letter and have the following comment.
 Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe  our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to this comment,  we may have additional comments.
 General

1. Please amend your registration statement to disclose the information you provided in response to our prior comments 2 through 9.  With respect to our prior comment 7, we
believe the information you provided in the th ree bullet points should be disclosed in the
registration statement.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  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.

Theodore D. Zucconi, Ph.D.
Pro-Pharmaceuticals, Inc.
October 14, 2010 Page 2

Please contact Sebastian Gomez Abero at ( 202) 551-3578 or Daniel Greenspan at (202)
551-3623 with any questions.
Sincerely,
       Jeffrey Riedler
Assistant Director