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CORRESP
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      Correspondence letter re 2004 10-KSB.

    December
      5, 2005

    Mr.
      Jim
      B. Rosenberg

    United
      States

    Securities
      and Exchange Commission

    450
      Fifth
      Street, N.W.

    Washington,
      DC 20549

    Re:    Stellar
      Pharmaceuticals Inc.

         Form
      10-KSB for fiscal year ended December 31, 2004

         File
      No.
      000-31198

    In
      response to your letter which was sent to me by fax on November 23, 2005, you
      will find below the detailed information as requested in your
      letter.

    Issue
      1.
      - Research and Development, page 24

    In
      2004
      Stellar moved its manufacturing process to Dalton Pharma Services located in
      Toronto, Ontario Canada. This new manufacturing facility required developing
      new
      process techniques and equipment which would facilitate the production of larger
      batch sizes. This entailed validation of new processes to ensure consistency
      in
      the end product. In addition, the Company also developed new product
      formulations which required further investment in processes for these new
      formulations.

    Issue
      2.
      - Controls and Procedures, page 28, Item 8a.

    The
      Company's Chief Executive Officer and Chief Financial Officer evaluations
      concluded that the Company's disclosure controls and procedures are
      effective.

    Issue
      3.
      - The policy as recorded on page 6 as Notes to the Financial Statement relates
      to the foreign currency transactions and therefore should read as
      below:

    Summary
      of Significant Accounting Policies - Foreign Currency
      Transactions

    Monetary
      assets and liabilities are translated in the functional currency (Canadian
      dollars) of the company at the year-end exchange rate, while foreign currency
      revenues and expenses are translated at the exchange rate in effect on the
      date
      of the transaction. The resultant gains or losses are included in income.
      Non-monetary items are translated at historical rates.

    The
      Company hereby acknowledges 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.

    Yours
      truly,

    Chief
      Financial Officer

    Stellar
      Pharmaceuticals Inc.