SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

November 30, 2005

Mr. Robert C. Low
Vice President, Finance and
Acting Chief Financial Officer
Advancis Pharmaceutical Corporation
20425 Seneca Meadows Parkway
Germantown, MD 20876

Re:	Advancis Pharmaceutical Corporation
	Form 10-Q for the Fiscal Period Ended September 30, 2005
	File No. 000-50414

Dear Mr. Low:

      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 document.  In our comment, we ask you to
provide us with information so we may better understand your
disclosure.  Please be as detailed as necessary in your
explanation.
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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-Q - September 30, 2005

Item 1.  Financial Statements (Unaudited), page 2

9.  Private Placement of Common Stock, page 12

1. We note that the warrants issued in connection with this
private
placement contain registration rights that require the payment of
liquidated damages as a result of the failure to maintain an
effective registration statement.  It appears that these
liquidated
damages represent a penalty for failure to maintain an effective
registration statement due to the significant amount that is
required
as repayment under this agreement.  Please explain to us how you
arrived at the conclusion under EITF 00-19 that these warrants
were
appropriately classified within permanent equity.  We note that
EITF
05-4 that you referenced in this note related to this issue is not
finalized and does not include any accounting treatment at this
time.
Refer to paragraph 16 of EITF 00-19.

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
letter
that keys your response to our comment and provide the requested
information.  Detailed letters greatly facilitate our review.
Please
file your letter on EDGAR under the form type label CORRESP.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing 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 investment 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 your letter, 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 Tabatha Akins, Staff Accountant, at (202)
551-
3658 or Jim Atkinson, Accounting Branch Chief, at (202) 551-3674
if
you have questions regarding comments on the financial statements
and
related matters.  Please contact me at (202) 551-3679 with any
other
questions.

Sincerely,

Jim B. Rosenberg
Senior Assistant Chief
Accountant
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Mr. Robert C. Low
Advancis Pharmaceutical Corporation
November 30, 2005
Page 3

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