SecProbe.io

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      August 11, 2005

      Ms. Tia Jenkins
      Senior Assistant Chief Accountant
      Office of Emerging Growth Companies
      Securities and Exchange Commission

      Re:   Larrea Biosciences Corporation
            File Number 000-50281
            Correspondence filed 04/06/05
            Form 10-Q9B/A filed 04/06/05
            Form 10-QSB filed 04/05/05
            Form 8-K/A filed 04/00/04,  amended 03/29/05
            Form S-K filed 03/28/05
            Form 8-K filed 09/21/04
            Form 10-KSB/A filed 08/30/04

      Dear Ms. Jenkins:

      Please accept the following information in response to your most recent
      letter dated April 21, 2005. As requested we have maintained the format
      you provided and have included the original question as part of the
      response.

      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 Item 3 10(c) and (d) of Regulation S-B or to us
      why such information is not required.

      Because the former owners/management of Larrea Biosciences Corporation
      failed to prepare or have audited pre-merger financial statements for
      LarreaRx, Inc. , a private company at the time, we are unable to provide
      audited financial statements for the acquired company. As our auditors
      have stated in their audit opinion on Larrea Biosciences, there was no
      inventory observation at the time of the merger and they were unable to
      satisfy themselves regarding inventory quantities by means of other
      auditing procedures. Based on the limited activity of LarreaRx, Inc. in
      its pre-merger form and the subsequent audit and filing of the Larrea
      Biosciences Corporation's Form 10-KSB , the Company and its auditors
      believe that further efforts to produce meaningful and reasonably accurate
      financial statements would not generate any materially useful information
      for investors or management. The Company there fore respectfully request
      that compliance with this item be considered satisfied by the submission
      of the current audited financial statements.

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      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.

      Noted for future filings.

      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)(l)) a discussion of any disagreements through the date of
      resignation (Item 304(a)(l)(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)).

      We have requested the letter from Madsen & Associates. To date, neither we
      nor our auditors have received any response to our telephone calls or
      written communications to either agree or disagree with the positions that
      have been taken. Given the limited activity of the Company during the time
      period Madsen were the auditors, further efforts to obtain a statement
      from Madsen are not likely to be successful or to yield any material
      information for investors .

      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.

      We have notified the auditors of your request and have asked them to
      comply.

      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 in 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 AP 20 Obtain an updated audit report, as
      necessary to comply with AICPA Auditing Standards Section 56 1.06a, with
      dual dating of the audit report necessary in some circumstances.

      The changes requested have been made and submitted as the attached Exhibit
      5.0.

      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 Larreacorp. Tell us
      supplementally of the relationship between the Company, GBI, LarreaRx and
      Larreacorp. 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.).

            a.) The relationship between the companies mentioned above is as
            follows.:

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i.    Presently Larrea Biosciences Corporation owns 100% of Global Botanics,
      Inc. and LarreaRx, Inc.. Peter P. Smetek, Jr. in his role as Chief
      Executive Officer of Larrea Biosciences Corporation is the sole officer
      and director of LarreaRx, Inc. and Global Botanics, Inc. He is not and
      officer, director or shareholder of Larreacorp, Ltd. The history of the
      relationship between these entities is set out below.

ii.   Larreacorp, Ltd. is a privately-held company created to develop patentable
      applications for extracts of the Larrea Tridentata plant. It was formed
      and owned by Robert Sinnott, PhD. who is also a shareholder and director
      of Larrea Biosciences Corporation. He is the primary inventor of the
      patents which create the proprietary formulation of Larrea tridentata
      extract used as the key ingredient in the dietary supplements marketed and
      sold by Larrea Biosciences Corporation, the publicly traded corporation
      which is the subject of this request. Larreacorp, Ltd. continues to be
      owned by Mr. Sinnott. Currently, there are no contracts or other active
      relationships between these two companies. Larrea Biosciences Corporation
      and its subsidiaries do not own any stock in Larreacorp, Ltd. and other
      than Mr. Sinnott none of the directors and officers of Larrea Biosciences
      Corporation are officers or directors of Larreacorp, Ltd.

iii.  Global Botanics, Inc. (GBI) was originally formed as a privately-held
      company owned by Mr. Sinnott to manufacture and commercialize the patented
      Larrea tridentata extract using the patents owned by Larreacorp, Ltd.. GBI
      had the exclusive rights to license the patents held by Larreacorp Ltd..

      1.    GBI licensed the patents to LarreaRx, Inc. which at the time of the
            licensing was a privately-held Wyoming corporation formed by
            unrelated third parties to incorporate the patented extract into
            dietary supplements.

      2.    GBI had also entered into an agreement with Larreacorp, Ltd. to
            purchase the related patents outright over time from Larreacorp,
            Ltd. GBI and Larreacorp, Ltd. had common ownership with Robert
            Sinnott and his family as 100% owners , officers and directors of
            both.

      3.    The third party shareholders of LarreaRx, Inc. acquired a
            publicly-traded company named Sonic Media, Inc. through a reverse
            merger and renamed it Larrea Biosciences Corporation ("LBC").
            LarreaRx, Inc. became a 100% owned subsidiary of LBC.

            a.    LBC, through its subsidiary LarreaRx Inc.'s business, was
                  expanding the sales of its Larrea tridentata extract products
                  and it wanted to become more than a licensee. In order to gain
                  the rights to the patents it currently used in its products
                  under a licensing relationship with GBI,. LBC acquired GBI in
                  a share exchange transaction and became the owner of the
                  patents and assumed GBI's rights under the patent purchase
                  agreement GBI had with Larreacorp, Ltd. As a result of the
                  share exchange GBI became a 100%

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                  owned subsidiary of LBC and Robert Sinnott became an officer,
                  director and shareholder of Larrea Biosciences Corporation in
                  2004. Mr Sinnott resigned from the board of directors of
                  Larrea Biosciences Corporation as of May 16, 2005.
            b.    As part of the acquisition transaction a third party investor
                  agreed to pay the scheduled cash payments under the patent
                  purchase agreement between GBI and Larreacorp, Ltd.. in
                  exchange for a certain number of shares of LBC stock. LBC
                  provided the stock and eliminated its cash obligations under
                  the purchase agreement note.
            c.    Larreacorp, Ltd. was not acquired by Larrea Biosciences
                  Corporation and remains a privately held company owned by Mr.
                  Sinnott.

      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:

      o     The basis of determining the amounts shown in the balance sheet,
            such as cost
      o     Balances of major closes of depreciable property presented by nature
            or function at the balance-sheet date
      o     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
      o     The amount of depreciation expense for each year for which an income
            statement is presented

      In the current Form 10-KSB the disclosures provided in the audited
      financial statements for the year ended April 30, 2005 under Note 3 and
      Note 7 provide the information requested.

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

      On January 31, 2005 there were accrued expenses of $10,700 representing
      audit fees for the Company's auditor LDMB Advisors, Inc. The balance of
      the entry was accounts payable.

      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 SMI's $ million note issued to Larrea Corp for its
            patents and the note's subsequent assumption by GBI shareholders for

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            50,000 shares. Address the issues raised in our prior comment and
            include appropriate references to relevant authoritative guidance in
            your response. The details of the changes are utlined in Note 4 of
            the audited financial statements for year ended April 30,2005.

            a.    By treating GBI as the acquiror the treatment of the note
                  changed and there was not a loss recognized.
            b.    SMI Re, Inc. did not provide a note to GBI or Larrea
                  Biosciences Corporation for the acquisition of the patent
                  rights. The note between Larreacorp and GBI for the
                  acquisition of the patent rights was in place prior to the
                  merger of GBI and Larrea Biosciences. The obligations under
                  this note were subsequently assumed by a third party in
                  exchange for shares in Larrea Biosciences shares. (See item 6
                  and 17).
            c.    A note was not assumed by GBI shareholders regarding the
                  patents.

      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.

      These changes were made and filed in the Company's current year
      Form 10-KSB filing.

      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.

      The changes are reflected in the Form 10-KSB for the year ended April 30,
      2005 in the audited financial statements Note 4. Restatement of Prior
      Years.

      Footnotes

      12. Please revise the statement of cash flows to appropriately present the
      financing activities related to the apparent overdraft of cash of $55,590
      as of October 31, 2003. It appears the cash balance as of October 31,
      2003, should be reported.

      The Statement of Cash Flows in the Form 10-KSB for April 30, 2005 reflects
      the items impacting cash flow for the operating history of the Company.

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

      The corrections and changes to the prior financial statements are
      disclosed in Note 4 to the audited financial statements, Restatement of
      Prior Years .

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      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.

      Larrea's products are all based on the extract from the Larrea Tridentata
      plant. It produces the extract in the form of capsules, lotion and a
      spray. For each of these three forms of the product the initial raw
      material is a semi-liquid resin derived directly from the plant. This
      resin is produced by using the Company's proprietary extraction method .

            a.    Resin is purchased from a contract producer that gathers the
                  leaves, dries them and the n manufactures the resin. Resin is
                  typically purchased in lots of 100 - 200 kilograms and is held
                  in that raw form on the pre