SecProbe.io

Via Facsimile and U.S. Mail
Mail Stop 4720

         March 12, 2010

Harvey Lalach
President, Chief Financial Officer,
Secretary and Director
Anavex Life Sciences Corp.
27 Marathonos Ave.,
15351 Athens, Greece

Re:    Anavex Life Sciences Corp.
 Form 10-K for the Fiscal Year Ended September 30, 2009
          File Number:  000-51652

Dear Mr. Lalach:

We have reviewed your filing and have the following comments.  In our
comments, we ask you to provide us with  information to better understand your
disclosure.  Where our comment requests you to revise disclosure, the information you
provide should show us what the revised disc losure will look like and identify the annual
or quarterly filing, as appli cable, in which you intend to fi rst include it.  If you do not
believe that revised disclosure  is necessary, explain the reason in your response.  After
reviewing the information provided, we may raise additional comments and/or request
that you amend your filings.

 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 on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Item 2. Properties, page 29
 1. We note that your disclosure here indicates  that the research facility the Company
rents from Eurogenet Labs houses a ll of Anavex’s operations, including
administration, research and developm ent, for a lease of $70,000 per month.
However, in “Results of Operations” on pa ge 33, you disclose that the lease expired
during 2008 and that, as a consequence, you pa id no rental or administration fees for
the year ended September 30, 2009 and only $75,000 for the previous year.  Please
revise your disclosure  to rectify this apparent disc repancy.  If you have not been
paying rental fees to Eurogenet Labs since 2008, please disclose the information

Harvey Lalach
Anavex Life Sciences Corp.
March 12, 2010
Page 2
required by Item 2 of Form 10-K as to your  facilities for the y ear ended September
30, 2009 and currently.  In addition, please file as an exhibit any contractual
arrangement you have, whether oral or writ ten, relating to your current facilities.

Consolidated Financial Statements
Report of Independent Regist ered Public Accounting Firm
 2. Your consolidated financial statements  were audited by BDO Dunwoody LLP located
in Vancouver Canada.  Please explain to us  why the audit report was issued in
Canada, given that you appear to have  no operations in Canada and you are
incorporated in the U.S.   Please address th e following to explain to us why Canada is
the appropriate location to  issue the audit report:
• Based on your disclosure, it appears most of your operations, including
administration and research and developm ent, are located in Athens, Greece.
Please tell where the majority of your  management and assets are located.
• Tell where your accounting records are lo cated and where the majority of the
audit work was conducted.
• Please have your auditor e xplain to us how they pe rformed the audit of the
international operations and to what exte nt, if any, other auditors were relied
upon.
 Notes to the Consolidated Financial Statements

Note 2.  Significant Accounting Policies
Foreign Currency Translation, page 2
 3. Please revise your disclosure to identify your  functional currency.  Please tell us how
the functional currency was determined.  Please also tell us whether any cash was
held in other currencies and if so, why your  statement of cash flows does not disclose
the effect of exchange rate changes on cas h balances held in fo reign currencies as a
separate part of the reconc iliation of the change in cash and cash equivalents during
the period.

*    *    *    *

 Please provide us the information request ed within 10 busine ss days or tell us
when you will provide us with a response.  Pl ease furnish a cover le tter with your response
that keys your response to our comments.  De tailed cover letters gr eatly facilitate our
review.  Please furnish your letter on 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

Harvey Lalach
Anavex Life Sciences Corp.
March 12, 2010
Page 3
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 a ny action with respect to the filings;
and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

 In addition, please be advi sed that the Division of En forcement 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 Dana Hartz, Sta ff Accountant, at (202) 551-3648 or Don
Abbott, Senior Staff Accountant, at (202) 551-3608 if you have any questions regarding
the processing of your response as well as  any questions regarding comments on the
financial statements and related matters. Y ou may contact Scot Foley, Staff Attorney, at
(202) 551-3383 or Dan Greenspan, Special Co unsel, at (202) 551-3623 with questions on
any of the other comments.  In this regard, do not hesitate to cont act me, at (202) 551-
3679.
        S i n c e r e l y ,

        J i m  B .  R o s e n b e r g
Senior Assistant Chief
Accountant