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Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                   February 11, 2008   Mr. Harvey Lalach President, CFO, Secretary and Director Anavex Life Sciences, Inc. 14 Rue Kleberg CH-1201 Geneva, Switzerland
Re: Anavex Life Sciences, Inc.
Form 10-KSB for the Fiscal Year Ended September 30, 2007
 File No. 000-51652

Dear Mr. Lalach:

We have reviewed your filing and have the following comment. We have limited
our review to your financial statements a nd related disclosures and do not intend to
expand our review to other portions of your document. After reviewing the information
provided, we may raise additional comments and/or request that you amend your filing.

 Please understand that the purpose of our re view 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.
 Report of Independent Regist ered Public Accounting Firm

1. Since the report filed does not contai n a typed signature of Amisano Hanson,
Chartered Accountants, please confirm that they provided a manually signed
report that is the same as the one in cluded in your filing and that you have
retained it for your records.  Confirm to  us that future reports will include the
typed signature of your independent accountants.

***************************

Mr. Harvey Lalach
Anavex Life Sciences, Inc. February 11, 2008 Page 2
 Please respond to this comment within 10 business days or tell us when you will
provide us with a response.  Please furnish a letter that keys your response to our
comment and provide the request ed information.  Detailed le tters greatly facilitate our
review.  Please furnish the letter to us via EDGAR under the form type label CORRESP.

 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 in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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 co mments, please provide, in your letter, 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 advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 You may contact Sasha Pa rikh, Staff Accountant, at (202) 551-3627 or Lisa
Vanjoske, Assistant Chief Accountant, at ( 202) 551-3614 if you have questions regarding
the comment.  In this regard, do not he sitate to contact me at (202) 551-3679.
  Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant