SecProbe.io

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MAIL STOP 05-11

      April 21, 2005

Mr. Peter P. Smetek, Jr.
Chief Executive Officer
Larrea Biosciences Corporation
400-55 Water Street
Vancouver, British Columbia V6B1A1
Canada

Re:	Larrea Biosciences Corporation
      File Number 000-50281
      Correspondence filed 04/06/05
      Form 10-QSB/A filed 04/06/05
      Form 10-QSB filed 04/05/05
      Form 8-K/A filed 04/09/04, amended 03/29/05
      Form 8-K filed 03/28/05
      Form 8-K filed 09/21/04
      Form 10-KSB/A filed 08/30/04

Dear Mr. Smetek:

	We have reviewed your filings and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
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 the applicable staff person at the
telephone number listed at the end of this letter.

Form 8-K filed September 21, 2004
1. We note your response to comment 5.  The financial statements
required by Item 9.01 of Form 8-K should be filed in an amendment
no
later than 75 days after the completion of the acquisition.
Please
amend this filing to include the pre-merger financial statements
of
LarreaRx, Inc. and other information prescribed by Items 310(c)
and
(d) of Regulation S-B or explain to us why such information is not
required.

Form 8-K filed March 28, 2005
2. In future filings, please note that a change in principal
independent accountant is considered an Item 4.01 event under the
Form 8-K rules.

3. Please revise to include disclosures in accordance with Item
304
of Regulation S-B.  These revisions should include a discussion
related to the accountant`s report on the financial statements of
the
Company (Item 304(a)(1)), a discussion of any disagreements
through
the date of resignation (Item 304(a)(1)(iv)(A)) and a discussion
related to any consultations with LDMB Advisors through the date
of
engagement (Item 304(a)(2)).  As Exhibit 16 to your revision,
include
a letter from Madsen & Associates indicating their agreement or
disagreement with statements made in your amended Item 4.01 Form
8-K
(Item 4(a)(3)).

Form 8-K/A filed March 29, 2005
4. Please ask the independent auditors of GBI to revise their
report
to present the name and electronic signature of the audit firm.

5. We note $986,111 in patents on the balance sheet as of April
30,
2004.  Revise the financial statements to report the historical
cost
of the patents, as reflected in your response to our prior comment
6
and the related revisions made to the Form 10-QSB for October 31,
2004.  Provide a note to the financial statements that explains
all
revisions made, in accordance with paragraph 37 of APB 20.  Obtain
an
updated audit report, as necessary to comply with AICPA Auditing
Standards Section 561.06a, with dual dating of the audit report
necessary in some circumstances.

Form 10-QSB/A, for the quarter ended October 31, 2004, filed April
6,
2005
6. We reviewed your response to comment #6, noting the value of
the
patents is now recorded at the historical cost of Larrea Corp.
Tell
us supplementally of the relationship between the Company, GBI,
LarreaRx and Larrea Corp.  Include in your response details of
common
directors and shareholder (e.g. the shareholders of Company X own
X%
of Company Y and the majority of Company X`s directors are 100% of
the directors of Company Y, etc.).

Financial Statements
7. In accordance with paragraph 5 of APB 12, revise the
disclosures
of depreciable assets and depreciation in the financial statements
or
notes thereto to include:
* The basis of determining the amounts shown in the balance sheet,
such as cost
* Balances of major classes of depreciable property presented by
nature or function at the balance-sheet date
* Accumulated depreciation presented by major classes of assets or
in
total at the balance-sheet date
* A description of the method(s) used to compute depreciation for
major classes of depreciable assets
* The amount of depreciation expense for each year for which an
income statement is presented

8. Disclose the nature and amount of the major components of
accrued
expenses in a note or state them separately on the balance sheet
for
the periods presented.

9. We reviewed your response to comment #15 indicating a different
treatment of the $200,000 loss on debt settlement.  Upon review of
the April 2004 balance sheet presented in Form 10-QSB, it appears
the
$200,000 loss on debt settlement is included in the retained
deficit
balance of $1,170,375.  Also, we note a $200,000 loss on debt
settlement has been reported on the statement of operations of GBI
for the period ending April 30, 2004, included in the Form 8-K
filed
on March 29, 2005.  Please explain to us supplementally the
Company`s
treatment of the $1.2 million note issued to Larrea Corp for its
patents and the note`s subsequent assumption by GBI shareholders
for
50,000 shares.  Address the issues raised in our prior comment and
include appropriate references to relevant authoritative guidance
in
your response.

10. The stockholders` equity accounts on the April 30, 2004
balance
sheet, do not agree with the amounts reported on the statement of
stockholders` equity as of April 30, 2004.  Revise to
retroactively
restate the equity section of the balance sheet and the statement
of
stockholders` equity to reflect the effect of the exchange ratio
established in the merger agreement.

11. Since Global Botanics, Inc. is considered the accounting
acquiror, the accumulated deficit should equal that of GBI for
periods prior to the merger.  Please revise to report the
accumulated
deficit of Global Botanics, Inc. as of April 30, 2004.  The
accumulated deficit as of October 31, 2004, should equal the
accumulated deficit of GBI at the date of the merger, adjusted for
transaction costs, if any, and for the net loss for the period
after
the merger.  Please revise as necessary.

12. Please revise the statement of cash flows to appropriately
present the financing activities related to the apparent overdraft
of
cash of $5,590 as of October 31, 2003.  It appears the cash
balance
as of October 31, 2003, should be reported as zero.

Footnotes
13. Provide a note to the financial statements that explains the
revisions that were made.  Refer to paragraph 37 of APB 20.

14. Please revise to include a discussion of the major components
of
inventory (raw materials, work-in-progress, finished goods, etc.)
and
a discussion of the amount and determination of a reserve for
obsolescence, if any.

15. According to Note 6, an additional 190,631 shares of the
Company`s common stock were issued to the shareholders of
LarreaRx,
subsequent to October 31, 2004.  Please explain supplementally the
basis for the additional share issuance and its delay.

MD&A
16. Revise to include a discussion of cost of sales and gross
margin,
including any expected future trends.

17. Upon review of Note 8 of GBI`s financial statements, it
appears
the $1.2 million note to Larreacorp was in default as of September
21, 2004, the date of the audit opinion.  Please update Note 7 of
the
financial statements for the quarter ended October 31, 2004 to
reflect this payment commitment.  If the note is in default at
October 31, 2004, revise MD&A to include a discussion of the
current
status of this note and management`s plans to address the default.
For guidance on this discussion, please refer to section IV C. of
SEC
Release No. 33-8350.

Form 10-QSB/A, for the quarter ended January 31, 2005, filed April
5,
2005
18. Please revise this Form 10-QSB for the period ended January
31,
2005 as necessary to address the above comments on the Form 10-QSB
for the quarter ended October 31, 2004.

19. Upon review of Note 4 - Promissory Note, it appears the
Company
was to pay principal and interest installments of $15,000 each on
November 30, 2004 and December 31, 2004 and $25,000 on January 31,
2005.  Upon review of the Statement of Cash Flows, there does not
appear to be any outflows associated with this payment.  Thus the
Company appears to be in default on this note. If the note is in
default at January 31, 2005, revise MD&A to include a discussion
of
the current status of this note and management`s plans to address
the
default.

      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 they have provided all information investors require
for
an informed decision.  Since the registrant and its management are
in
possession of all facts relating to a registrant`s disclosure,
they
are responsible for the accuracy and adequacy of the disclosures
they
have made.

      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 make appropriate revisions in response to these
comments.  Please furnish a cover letter with your revisions that
keys your responses to our comments and provides any requested
supplemental information.  Detailed cover letters greatly
facilitate
our review. These revisions and the letter should be filed on
EDGAR
no later than May 5, 2005.  Please understand that we may have
additional comments after reviewing your revisions and responses
to
our comments.

      You may contact Brian K. Bhandari at (202) 551-3390 or
Terence
O`Brien at (202) 551-3355 if you have questions regarding comments
on
the financial statements and related matters.

						Sincerely,

						Tia Jenkins
						Senior Assistant Chief Accountant
						Office of Emerging Growth Companies
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