SecProbe.io

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                            Bio-Bridge Science, Inc.
                        1211 West 22nd Street, Suite 615
                               Oak Brook, IL 60523
                                Tel: 630-928-0869

                                   May 2, 2005

VIA EDGAR AND COURIER

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, NW
Washington DC, 20549

Attn: Jonathon E. Gottlieb, Esq.
      Mark Webb, Esq.

      RE:   BIO-BRIDGE SCIENCE, INC.
            REGISTRATION STATEMENT ON FORM SB-2
            FILE NO. 333-121786

Messrs. Gottlieb and Webb:

      We enclose for filing under the Securities Act of 1933, as amended,
Amendment No. 1 to the above-referenced registration statement (the
"Registration Statement") together with exhibits thereto. Amendment No. 1 to the
Registration Statement contains revisions that have been made in response to
comments received from the staff ("Staff") of the Securities and Exchange
Commission in their letter dated January 28, 2005. Set forth below are
Bio-Bridge Science, Inc's (the "Company") responses to the Staff's comments. We
have reproduced the Staff's comments in bold type and have followed each comment
with our response. References in this letter to "we," "our" or "us" mean the
Company or its advisors, as the context may require. Clean and marked copies of
Amendment No. 1 to the Registration Statement are being provided supplementally
under separate cover.

GENERAL

      1.    DISTINGUISH BETWEEN YOUR PLANS FOR THE FUTURE AND THE FACTS OF THE
            PRESENT AS OF THE DATE OF YOUR FILING. FOR INSTANCE, ON PAGE 13,
            REVISE YOUR STATEMENT THAT "YOUR OPERATIONS ARE PRIMARILY LOCATED IN
            CHINA" TO REFLECT THE FACT THAT YOU HAVE NO OPERATIONS AT THIS TIME.

            We have revised our disclosure in the Prospectus Summary section and
            on page 13 of the prospectus to clarify that we have operations in
            China through our subsidiary, Bio-Bridge Science (Beijing) Co. Ltd.,
            a Wholly-Foreign Funded Enterprise of the People's Republic of
            China.

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Securities and Exchange Commission
May 2, 2005
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      2.    PLEASE REVISE THE DOCUMENT TO COMPLY WITH ITEM 10(C) (1) OF
            REGULATION S-B INCLUDING THE FOLLOWING REQUIREMENTS:

            o     PRESENT INFORMATION IN "CLEAR CONCISE AND UNDERSTANDABLE
                  FASHION;" AND

            o     AVOID USE OF TECHNICAL LANGUAGE.

            In response to the Staff's comment, we have deleted the glossary of
            scientific terms and have revised our disclosure throughout the
            prospectus to avoid the use of technical language and to present the
            information in "clear concise and understandable fashion."

      3.    PLEASE INCLUDE AN UPDATED CONSENT OF THE INDEPENDENT AUDITORS IN THE
            PRE-EFFECTIVE AMENDMENT.

            We have included and will include an updated consent of the
            independent auditors in each pre-effective amendment.

      4.    PLEASE NOTE THE UPDATING REQUIREMENTS OF ITEM 310(G) OF REGULATION
            S-B.

            Noted. The Company has provided and will provide updated financial
            information pursuant to Item 310(g) of Regulation S-B.

SUMMARY - PAGES 3-4

      5.    PLEASE REVISE YOUR SUMMARY TO GIVE MORE PROMINENCE TO MATERIAL
            INFORMATION ABOUT THE COMPANY AND THE OFFERING. FOR EXAMPLE, THE
            DISCUSSION OF THE REVERSE MERGER THAT OCCUPIES MOST OF THE SECOND
            PARAGRAPH DOES NOT APPEAR MATERIAL ENOUGH TO BE IN THE SUMMARY.

            We have revised the Summary and deleted the detailed discussion of
            the reverse merger in this section.

      6.    THE INFORMATION IN THE SUMMARY SHOULD BE BALANCED. PLEASE REVISE.

            In response to the Staff's comment, we have revised the information
            in the Summary.

SUMMARY FINANCIAL DATA - PAGE 5

      7.    PLEASE REVISE TO DISCLOSE THAT THE FINANCIAL INFORMATION PRESENTED
            IS THAT OF A DEVELOPMENT STAGE COMPANY.

            We have revised our disclosure to clarify that the financial
            information presented is that of a development stage company.

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Securities and Exchange Commission
May 2, 2005
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      8.    PLEASE REVISE TO PRESENT THE COLUMNS OF INTERIM FINANCIAL
            INFORMATION BEFORE THE COLUMNS OF ANNUAL FINANCIAL INFORMATION.
            REFER TO SAB TOPIC 11:E.

            Please note that interim financial information is not required in
            Amendment No. 1 to the Registration Statement. However, with respect
            to future amendments, we will present the interim financial
            information before the columns of annual financial information.

RISK FACTORS - PAGES 5-11

      9.    SOME OF YOUR RISK FACTORS STATE THAT YOU "CANNOT GIVE ASSURANCE" OR
            THAT THERE "IS NO ASSURANCE" OF SOMETHING WHEN THE RISK IS NOT YOUR
            INABILITY TO GIVE ASSURANCE BUT THE SITUATION BEING DESCRIBED.
            PLEASE REVISE TO ELIMINATE THIS AND SIMILAR LANGUAGE.

            We have revised our risk factors to eliminate the referenced and
            similar language.

      10.   PLEASE REVISE THE RISK FACTOR ON PAGE 8 TO REPLACE YOUR REFERENCE TO
            THE HIV VACCINE AS "OUR MAIN PRODUCT CANDIDATE" WITH A REFERENCE TO
            IT AS "OUR SOLE PRODUCT CANDIDATE."

            In response to the Staff's comment, we have replaced the referenced
            language with "our sole product candidate."

DIRECTORS, EXECUTIVE OFFICERS, PROMOTERS, AND CONTROL PERSONS - PAGE 19

      11.   PLEASE STATE IF YOU HAVE A SEPARATELY STANDING AUDIT COMMITTEE OR A
            COMMITTEE PERFORMING SIMILAR FUNCTIONS AND IDENTIFY EACH AUDIT
            COMMITTEE MEMBER. IF ALL MEMBERS OF THE BOARD AND AUDIT COMMITTEE
            MEMBERS THEN STATE SO. REFER TO ITEM 401(E) (2) OF REGULATION S-B.

            We have added disclosure to clarify that our board has not
            designated a standing audit committee. Since such committee does not
            exist, our board of directors constitutes the audit committee
            pursuant to Section 3(a)(58)(A) of the Exchange Act of 1934.

DESCRIPTION OF BUSINESS

HISTORY, REORGANIZATION AND CORPORATE STRUCTURE OF THE COMPANY - PAGE 24

      12.   PLEASE REVISE TO EXPAND YOUR DISCUSSION OF THE PURPOSE OF
            INCORPORATION OF BIO-BRIDGE DELAWARE. SPECIFICALLY STATE WHAT THE
            CORPORATE STRUCTURE WAS PRIOR THE INCORPORATION OF THE BUSINESS AND
            WHAT THE STRUCTURE OF THE BUSINESS CHANGED TO ONCE THE INCORPORATION
            TOOK PLACE.

            We have revised our disclosure to clarify that there was no change
            in corporate structure before and after the incorporation of
            Bio-Bridge Science, Inc., the Delaware corporation. It was
            established for the purpose of becoming a holding company for
            Bio-Bridge Science Corp. the Cayman Islands corporation.

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Securities and Exchange Commission
May 2, 2005
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      13.   PLEASE REVISE TO DISCLOSE IF BIO-BRIDGE INC. EXPERIENCED A CHANGE IN
            MANAGEMENT DUE TO THE SHARE EXCHANGE.

            We have added disclosure to clarify that there was no change in
            management due to the share exchange. The directors and executive
            officers of Bio-Bridge Science, Inc. are the same directors and
            executive officers of Bio-Bridge Science Corp.

      14.   REVISE TO CLARIFY IF BIO-BRIDGE SCIENCE CORP. IS THE SAME COMPANY AS
            BIO-BRIDGE (CAYMAN).

            In response to the Staff's comment, we have deleted the term
            Bio-Bridge (Cayman) from the prospectus.

      15.   REVISE TO DISCLOSE THAT THE ASSETS AND LIABILITIES OF BIO-BRIDGE
            CAYMAN WERE CARRIED OVER AT HISTORICAL COST, IF TRUE.

            We have revised the disclosure to state that the assets and
            liabilities of Bio-Bridge Science Corp. were carried over at
            historical cost.

OVERVIEW OF HIV AND AIDS IN CHINA - PAGE 24

      16.   PLEASE REVISE TO DISCUSS THE TRENDS OF HIV AND AIDS IN THE USA AND
            JAPAN, THE OTHER INTENDED MARKETS FOR YOUR VACCINE.

            We have added disclosure regarding HIV and AIDS trends in the U.S.
            and Japan on page 25.

      17.   PLEASE REVISE TO SPECIFICALLY DISCLOSE ALL THE STEPS THE COMPANY
            MUST TAKE TO GET THE VACCINE APPROVED UNDER THE "GREEN MILE"
            POLICIES OF THE PEOPLE'S REPUBLIC OF CHINA. IN ADDITION, PLEASE
            DISCUSS THE SPECIFIC DIFFERENCES BETWEEN THIS PROCESS AND THE
            PROCESS OF DRUG APPROVAL IN JAPAN AND IN THE U.S.A.

            In response to the Staff's comment, we have revised our disclosure
            to disclose all the steps that we must take to obtain regulatory
            approval of our HIV-PV Vaccine I product candidate in China, Japan
            and the U.S.

      18.   REVISE TO SPECIFICALLY STATE IF YOU HAVE RECEIVED ANY FUNDING
            COMMITMENTS FROM THE CHINESE GOVERNMENT.

            We have added disclosure to clarify that we have not received any
            funding commitments from the Chinese government. However, we may
            apply for government funding in the future.

THE HIV INFECTION PROCESS AND THE ROLE OF MUCOUS MEMBRANE DURING INFECTION -
PAGE 25

      19.   PLEASE DEFINE THE "MUCOSAL SURFACE" IS.

            We have added disclosure to define the referenced term on page 25.

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Securities and Exchange Commission
May 2, 2005
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      20.   PLEASE REVISE THE SECTIONS ENTITLED "VACCINES," "THE HIV INFECTION
            PROCESS," AND "PRODUCTS UNDER DEVELOPMENT," ON PAGES 25 AND 26 TO
            MAKE MORE UNDERSTANDABLE. PLEASE AVOID USING ABBREVIATIONS.

            We have revised these sections to make the disclosure more
            understandable.

PRODUCTS UNDER DEVELOPMENT - PAGES 26

      21.   PLEASE REVISE TO DISCLOSE WHERE YOU ARE IN THE PRE-CLINICAL AND
            ANIMAL TESTING PHASE. SPECIFICALLY DESCRIBE WHAT EACH TEST IS, AND
            EXPLAIN WHETHER YOU HAVE COMPLETED THAT PHASE OF TESTING
            SUCCESSFULLY.

            We have revised our disclosure as requested.

PRODUCTS UNDER DEVELOPMENT - PAGES 26-27

      22.   PLEASE REVISE THE SECTION BRIEFLY DESCRIBE THE QUALIFICATIONS OF THE
            BEIJING INSTITUTE TO CONDUCT THESE TESTS.

            In response to the Staff's comment, we have added disclosure
            concerning Beijing Institute's qualifications to conduct these
            pre-clinical tests.

RESEARCH AND DEVELOPMENT - PAGE 27

      23.   PLEASE DISCLOSE IF THE LAND USE RIGHT IS EXTENDABLE BEYOND 50 YEARS.

            We have revised our disclosure to add that the land use right is
            extendable beyond 50 years for a fee of U.S.$78,780 for an
            additional 50 years.

INTELLECTUAL PROPERTY - PAGE 27

      24.   PLEASE DESCRIBE THE AMOUNT OF ROYALTY PAYMENTS PROVIDED FOR IN THE
            AGREEMENT.

            We have added disclosure concerning the royalty payments provided
            for in the agreement with Loyola University.

COMPETITION - PAGE 27

      25.   PLEASE REVISE THE SECTION AS FOLLOWS:

            o     DISCLOSE THE MOST ADVANCED STAGE THAT YOUR COMPETITORS HAVE
                  REACHED IN TESTING THEIR VACCINES;
            o     PROVIDE MORE DETAIL REGARDING THE ADVANTAGES OF YOUR
                  COMPETITORS INCLUDING THEIR EXPERTISE AND EXPERIENCE IN
                  DEVELOPING AND MARKETING VACCINES AND DRUGS; AND
            o     DISCUSS METHODS OF COMPETITION.

            In response to the Staff's comment, we have revised our disclosure
            to provide additional information regarding our competitors and
            methods of competition.

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Securities and Exchange Commission
May 2, 2005
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GOVERNMENT REGULATION AND PROBABILITY OF AFFECTING BUSINESS - PAGE 27

      26.   PLEASE REVISE THE SECTION AS FOLLOWS:

            o     EXPLAIN EACH OF THE STEPS INCLUDING THE DIFFERENCES BETWEEN
                  DIFFERENT PHASE CLINICAL STUDIES; AND
            o     DISCUSS THE STEPS REQUIRED IN JAPAN AND THE US AND PROVIDE AN
                  ESTIMATED TIME SCHEDULE.

            We have moved the discussion regarding government regulation of the
            drug approval process to page 25 of the prospectus.

      27.   REVISE TO DISCLOSE WHAT THE SPECIFIC POTENTIAL ENVIRONMENTAL HAZARDS
            ARE RESULTING FROM THE PRODUCTION AND RESEARCH EFFORTS.

            We have revised to clarify that we currently have no potential
            environmental hazards resulting from our research and development
            efforts.

      28.   PLEASE REVISE YOUR DISCUSSION OF THE REGULATORY APPROVAL PROCESS TO
            INCLUDE THE FOLLOWING:

            o     DISCUSS THE POTENTIAL ISSUES THAT MAY ARISE WHEN YOU SEEK
                  REGULATORY APPROVAL FROM THESE COUNTRIES IF YOU DEVELOP AND
                  OBTAIN GOVERNMENT APPROVAL FOR THE VACCINE IN CHINA FIRST.

            We have revised our disclosure on page 25 of the prospectus as
            requested.

      29.   PLEASE PROVIDE THE DISCLOSURE REQUIRED BY ITEM 101 (C) OF REGULATION
            S-B REGARDING PUBLIC ACCESS TO MATERIALS FILED WITH THE SEC.

            In response to the Staff's comment, we have revised the disclosure
            in compliance with Item 101(c) of Regulation S-B.

MANAGEMENT'S DISCUSSION AND ANALYSIS OR PLAN OF OPERATION

OVERVIEW - PAGE 28

      30.   PLEASE REVISE THE SECTION TO REDUCE THE REPETITION FROM THE BUSINESS
            SECTION. PLEASE MENTION THE GOING CONCERN ISSUE AT THE OUTSET OF THE
            SECTION.

            We have revised the disclosure as requested.

      31.   PLEASE DISCLOSE WHY YOU HAVE NO COMMITMENTS TO MAKE PAYMENTS FOR AN
            UNCOMPLETED LABORATORY FACILITY. REVISE TO DISCLOSE THE AMOUNT OF
            PAYMENTS THAT YOU ANTICIPATE MAKING REGARDLESS OF WHETHER YOU HAVE A
            CONTRACTUAL COMMITMENT.

            We have revised our disclosure to clarify the amount of the
            contractual commitment.

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Securities and Exchange Commission
May 2, 2005
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GOING CONCERN - PAGE 29

      32.   PLEASE SPECIFICALLY STATE WHAT CERTAIN GOVERNMENT APPROVALS MUST BE
            OBTAINED, AND WHETHER OR NOT YOU HAVE RECEIVED ANY OF THESE
            APPROVALS. DISCUSS ALL REGULATORY APPROVALS THAT MUST BE OBTAINED IN
            EACH OF THE COUNTRIES YOU ANTICIPATE SELLING YOUR PRODUCT TO.

            We have deleted the referenced language from the MD&A section.
            Please see our discussion of the governmental regulations on page 25
            of the prospectus.

PLAN OF OPERATION - PAGE 29

      33.   PLEASE REVISE THE SECTION TO COMPLY WITH ITEM 303 (A) (1) INCLUDING
            THE FOLLOWING:

            o     A DISCUSSION OF HOW LONG YOU CAN SATISFY YOUR CASH
                  REQUIREMENTS; AND

            o     A SUMMARY OF PRODUCT RESEARCH AND DEVELOPMENT THAT YOU WILL
                  PERFORM OF THE TERM OF THE PLAN.

            In response to the Staff's comment, we have revised our disclosure
            as requested.

RESULTS OF OPERATIONS

NINE MONTHS ENDED SEPTEMBER 30, 2003 AND 2004 - PAGE 29

      34.   PLEASE REVISE YOUR DISCUSSION OF THE INCREASE IN EXPENSES TO INCLUDE
            THE REASONS WHY THE CHANGES ARE OCCURRING, AND INCLUDE A DISCUSSION
            OF WHY RESEARCH AND DEVELOPMENT COSTS INCREASED.

            We have revised our discussion of the increase in expenses for the
            fiscal year 2004 as compared to fiscal year 2003.

CRITICAL ACCOUNTING POLICIES AND ESTIMATES - PAGE 30

      35.   REVISE TO DISCLOSE THE TYPES OF RESEARCH AND DEVELOPMENT COSTS THAT
            REQUI