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CORRESP
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      Correspondence with the SEC

              4211
                Yonge Street, Suite 615

              Toronto,
                Ontario

              Canada
                M2P 2A9

              www.imimedical.com

    September
      14, 2005

    Mr.
      Jim B. Rosenberg

    Senior
      Assistant Chief Accountant

    Division
      of Corporation Finance

    United
      States Securities and Exchange Commission

     Washington,
      D.C. 20549

            Re:
            File No. 001-31360

            Form 20-F for the year ended December
              31,
              2004

            Form 6-K/A Filed October 21, 2004

    Dear
      Mr. Rosenberg:

    You
      have asked us to clarify the reference to Iran and Syria in the License,
      Development and Supply Agreement between IMI and McNEIL PDI Inc. and McNEIL
      Consumer & Specialty Pharmaceuticals Division of McNEIL-PPC Inc. (“McNEIL”).

    By
      way of background, this is a global agreement whereby IMI licensed the sales
      and
      marketing of its skin sterol technology, a medical device used as a predictor
      of
      cardiac risk, to McNEIL, a subsidiary of Johnson & Johnson Inc. Article 17.3
      of the agreement discusses the minimum sales for each territory covered by
      the
      agreement and 17.3 (e) specifically refers to the countries of Africa and the
      Middle East, and mentions Iran and Syria among the list of countries.

    First,
      let me explain that IMI only sells these products to its licensee, McNEIL,
      in
      Canada and the United States and does not sell directly to any other customers.
      McNeil is responsible for selling the products into the global community. IMI
      has no previous, existing or planned operations in Iran or Syria. Furthermore,
      I
      enclose a letter from McNEIL confirming that they have not conducted business
      with Iran or Syria and have no plans to conduct such business in the future
      as
      long as economic sanctions are in force.

    In
      making these statements, IMI acknowledges that:

              ·

              it
                is responsible for the adequacy and accuracy of the disclosure in
                this
                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

              ·

              it
                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.

    Sincerely,

    /s/
      Ron Hosking

    Ron
      Hosking, CA

    Vice
      President, Finance & CFO

    Mr.
      Ron Hosking

    Chief
      Financial Officer

    IMI
      International Medical Innovations Inc. ("IMI")

    42ll
      Yonge Street

    Toronto,
      ON M2P 2A9

    September
      9, 2005

    RE:
      Response to the letter sent to IMI by the United States Securities and Exchange
      Commission (the"SEC") dated September 2, 2005

    Dear
      Mr.
      Hosking:

    Thank
      you
      for forwarding to us the letter you received from the SEC dated September 2,
      2005. As a subsidiary of Johnson & Johnson Inc. ("J&J"), McNeil Consumer
      Healthcare ("McNeil") strictly follows J&J's policy regarding export
      regulations:

    J&J's
      policy is that all affiliates be aware of applicable export law and implement
      procedures and practices necessary to assure compliance with and adherence
      to applicable law when conducting international
      transactions.

    In
      accordance with this policy and U.S. export regulations, McNeil has not
      conducted business with Iran, Syria, or any other country where economic
      sanctions have been implemented against that country by the United States.
      Additionally, McNeil does not anticipate conducting business with any country
      where economic sanctions have been implemented against that country by the
      United States.

    Paragraph
      17.3(e) of the License, Development and Supply Agreement with IMI should not
      have included Iran and Syria in the list of "Middle East" countries because
      McNeil has not and will not conduct business with these countries as long as
      economic sanctions have been implemented against these countries by the United
      States.

    Sincerely,

    /s/
      Greg
      Josey

    Greg
      Josey

    Vice
      President of Finance

    McNeil
      Consumer Healthcare