SecProbe.io

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Mail Stop 6010

								December 19, 2005

Steven S. Porter
Chief Executive Officer
Ceragenix Pharmaceuticals, Inc.
1444 Wazee Street, Suite 210
Denver, Colorado 80202

	Re:	Ceragenix Pharmaceuticals, Inc.
		Schedule 14C filed November 21, 2005
		Form 8-K/A filed July 11, 2005
		Form 10-QSB filed November 21, 2005
		File No. 0-50470

Dear Mr. Porter:

	We have reviewed your filing 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.
Please be as detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with information so we
may
better understand your disclosure.  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.

SCHEDULE 14C

General

1. We note the statements in your document that you incorporate by
reference your Form 10-Q for the quarter ended September 30, 2005.
It
appears you are not S-3 eligible because you were late in filing
your
Form 10-Q for the quarter ended March 31, 2005.  Therefore, it
appears
you are not permitted to incorporate by reference your past
filings.
Please include all required information directly in the Schedule
14C
rather than incorporating it by reference.

2. It does not appear that you meet the requirements of Item 14(e)
of
Schedule 14A.  As a result, please furnish all of the pro forma
financial information related to your disposition of GAI required
pursuant to Item 14(b)(10) and (11) of Schedule 14A, deferring to
Item
310 of Regulation S-B as applicable.  See Note F to Schedule 14A.

3. Please provide the financial statements and other information
about
your company, as described in Item 14(c) of Schedule 14A, which
refers
to Part B of Form S-4.  Also, since Global Alaska Industries
appears
to be a significant business, please provide GAI`s unaudited
financial
statements and pro forma information.  See Section I.H, Question 6
of
the July 2001 Supplement to the Manual of Publicly Available
Telephone
Interpretations.

4. Item 3 of Schedule 14C refers to certain interests of persons
in
the transactions to be acted upon.  You have not disclosed any
such
interests in the filing.  Please provide this information to the
extent it is applicable.

5. Item 14 of Schedule 14A sets forth numerous required
disclosures
that you must make to stockholders in connection with this type of
transaction.  As currently prepared, your disclosure does not
properly
address these items.  You should present this disclosure in
narrative
form and provide significantly more detail for each item you have
listed.

6. Furthermore, you need to provide more information relating to
the
transaction, including the background of the transaction, the
reasons
that the board believes that the transaction is in the best
interests
of the stockholders, and tax and accounting treatment for the
transaction.  You also need to disclose how the consideration
amount
was determined, why a fairness opinion was not obtained, and the
basis
for the company`s belief that the transaction is in the best
interests
of stockholders.

Summary Term Sheet of Agreement for Sale of Assets

7. Your Summary Term Sheet disclosure does not provide sufficient
disclosure.  Item 14 of Schedule 14A and Item 1001 of Regulation
S-K
require that you disclose the material terms of the proposed
transaction and that you must provide security holders with
sufficient
information to understand the essential features and significance
of
the transaction.  Item 1001 also requires that you cross-reference
a
more detailed discussion of the proposed transaction, which should
be
part of the disclosure you furnish to security holders.  Your
Summary
Term Sheet disclosure does not disclose the material terms of the
proposed transaction.  Moreover, you have not included a more
detailed
discussion of the proposed transaction.  This more detailed
discussion
should include, but not be limited to, disclosure of all of the
material terms of the transaction, covenants, representations,
warranties, consideration, closing conditions, etc.  It should
also
discuss the significance of the transaction to the registrant and
security holders.  For example, often in asset sales, there are
working capital adjustment provisions, and other financial terms.
We
expect you to provide significantly more disclosure regarding the
transaction in response to this comment.

8. Please identify your principal shareholder in the last bullet
point
and the names of the beneficial owners of the entity.

Reasons for the Sale of GAI

9. Please explain how the board came to the conclusion that "the
pharmaceutical business represented a better opportunity than
those of
the gaming business."  Discuss any analyses the board performed.

10. Discuss any negative factors the board considered in
connection
with the asset sale.

Effects of the Sale of GAI

11. We note ABSI has not made any contribution to the operating
expenses of Ceragenix Pharmaceuticals, Inc.  Please disclose
whether
it has made any contribution to the revenues.  Disclose whether
ABSI
had any operations.

Contacts with Buyer

12. This discussion should be substantially expanded to describe
all
meetings and other contacts between the parties.  For each meeting
or
contact, state the date, and identify the attendees/participants
and
the items discussed.  See Item 14(b)(7) of Schedule 14A.  If
counsel
or financial advisors were present, identify those parties.

13. Please include the stock purchase agreement as an attachment
to
your filing.  See

Executive Offices

14. Please state Trans Alaska Holdings`s mailing address and
telephone
number.  See Item 14(b)(2) of Schedule 14A.

Security Ownership of Certain Beneficial Owners and Managements

15. Based on footnote 9, it appears Ceragenix`s board of directors
currently controls most of the shares held by Osmotics
Corporation.
Please identify the natural persons who have beneficial ownership
of
the other shares held by Osmotics Corporation.

FORM 8-K/A FILED JULY 11, 2005

Pro Forma Adjustments

16. We note your purchase price allocation and subsequent
recognition
of goodwill of $9.6 million in conjunction with the reverse
acquisition of OnSource Corporation.  Please provide us with
additional information, as follows.

* Clarify your inclusion of the valuation of the debenture and
placement warrants as purchase price, as it would appear that you
should view and account for these transactions separately.  Please
provide us with additional information to clarify your accounting
treatment, referencing the applicable authoritative accounting
literature.

* You mention throughout the disclosures regarding the merger that
OnSource issued warrants exercisable to purchase an aggregate of
1,079,472 of common stock at an exercise price of $2.18 per share.
Please tell us how the issuance of these warrants was included in
the
purchase price.

* In your valuation of the warrants for determination of the
purchase
price, you state that you used the market price of OnSource common
stock as of the date the merger became effective.  It would appear
that, consistent with paragraph 22 of SFAS No. 141, you should
base
the market price on a date that reflects a reasonable period of
time
before and after you agreed to and announced the terms of the
acquisition; that is, April 8, 2005.  Please specify the valuation
date for the issuance of the 970,858 shares of OnSource common
stock
and revise your purchase price calculation to reflect the impact
that
the change in the common stock price will have on the
determination of
the fair value of the warrants.

* It would appear that you impaired a significant portion of the
recognized goodwill soon after the merger.  This raises concern as
to
whether you should have recognized the goodwill at the time of the
merger.  Please provide us with additional information regarding
your
recognition and immediate impairment of the goodwill related to
the
transaction.  Please address paragraph 69 of Appendix B of SFAS
No.
142.

FORM 10-QSB FILED NOVEMBER 21, 2005

Condensed Consolidated Statements of Cash Flows, page 5

17. Please explain to us why the borrowings from OnSource prior to
the
merger are included in the statement of cash flows.  It would
appear
that you should have eliminated these borrowings during the merger
of
OnSource and Ceragenix.

Notes to Condensed Consolidated Financial Statements

Note (1) Business and Overview, page 8

18. Please provide us with additional information to clarify the
inclusion of the $925,000 "receivable from Ceragenix Corporation"
as
part of the purchase price allocation pursuant to the reverse
merger
with OnSource Corporation.  It would appear that this amount would
eliminate between the two entities.

Note (4) Licensed Technology Costs, page 11

19. We note that you recognize an asset for the filing,
prosecution,
perfection and maintenance of patent rights.  We believe that you
should expense these items as incurred pursuant to paragraph 10(i)
of
SFAS No. 2.  Please revise your financial statements accordingly.

*	*	*

	As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the
amendment to expedite our review.  Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested information.  Detailed cover letters greatly
facilitate
our review.  Please understand that we may have additional
comments
after reviewing your amendment and responses to our comments.

	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
writing, 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 Amy Bruckner at (202) 551-3657 or Joseph
Roesler
at (202) 551-3628 if you have questions regarding comments on the
financial statements and related matters.  Please contact Greg
Belliston at (202) 551-3861 or me at (202) 551-3715 with any other
questions.

								Sincerely,

								Jeffrey Riedler
								Assistant Director

cc:	Clifford L. Neuman, Esq.
	1507 Pine Street
	Boulder, Colorado 80302
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Steven S. Porter
Ceragenix Pharmaceuticals, Inc.
December 19, 2005
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