SecProbe.io

October 4, 2006

Mail Stop 6010

John S. Kovach
Chairman and Chief Executive Officer
SRKP 7, Inc.
248 Route 25A, No. 2
East Setauket, NY 11733

Re: SRKP 7, Inc.
Registration Statement on Form SB-2
Filed September 8, 2006
  File No. 333-137208

Dear Mr. Kovach:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise 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 deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.
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.

Form SB-2

Prospectus cover

1. Given that there is no market for your securities, please disclose the price at
which your selling shareholders will sell th eir securities.  See Schedule A Item 16
of the Securities Act and Regulation S-B Item  501(a)(9)(iv).  We will not object if
you also disclose that the se lling shareholders will sell at prevailing market prices
or privately negotiated prices after th e shares are quoted on the OTC Bulletin
Board.  Please also modify your “Plan of Distribution” disclosure accordingly.

John S. Kovach
SRKP 7, Inc.
October 4, 2006 Page 2
Prospectus Forepart

2. Please avoid reliance on defined terms lik e those in parentheses and quotation
marks.  If the terms are clear from cont ext, the definitions are unnecessary.  If
they are not clear, plea se revise for clarity.

Prospectus Summary, page 1

3. The introductory paragraph to your summa ry states that the summary is not
complete. A summary, by its very nature, does not and is not required to contain all of the detailed information that is in the prospectus. However, if you have
elected to include a summary in your pr ospectus, it must be complete. Do you
mean to say that, because this is a summary, it may not contain all of the
information that is important to your i nvestors? Delete the reference to an
incomplete summary from your prospectus.

Private Placement, page 2

4. With a view toward clarified disclosu re, please tell us why you issued the
placement agent two separate warrants with apparently the same terms.

Risk Factors, page 5

5. Please add a separate risk factor to hi ghlight the going concern language in your
auditor’s report.  Disclose the reason fo r the language and its material effects,
including its effect on your access to capital at market rates.

We depend on certain key scientific personnel…, page 8

6. Revise to quantify the amount of time that  Dr. Kovach devotes to your business.
7. In a separate risk factor, address the risk s associated with the fact that these key
personnel are involved in other business activities and may face a conflict in
selecting between their othe r business interests and you, as discussed on page 40.

John S. Kovach
SRKP 7, Inc.
October 4, 2006 Page 3
We expect to rely heavily on third parties for the conduct of clin ical trials…, page 8

8. Revise to clarify what steps you will need to achieve before you begin conducting preclinical studies and clinic al trials in humans.

If our products were derived from tissue or other samples from a patient…, page 13

9. In an appropriate section of your document,  please disclose when the negotiations
in the second sentence began.  Also disclose the status of th e negotiations and the
principal hurdles that remain befo re an agreement can be reached.
10. Revise to clarify whose obligation it will be  to obtain the necessary consents. Also
clarify why the consents might not be enforceable.

11. Please clarify why there is a material ri sk of willful misconduct.  Does your
supplier have a history of such conduct?

If we fail to maintain effective internal controls, page 17

12. We note the disclosure in the first sent ence that you “may” have weaknesses.
Please disclose the reasons for the doubt.

Standards for compliance with Section 404 of the Sarbanes-Oxley Act…, page 17

13. We note your belief that the compliance dates for you will first apply to your
annual report for fiscal 2008.  Your disc losure on page F-11, however, indicates
that you will be required to comply with these requirements with your year ending December 31, 2007.  Please revise as appropriate to reconcile.

Forward-Looking Statements, page 19

14. Please note that Section 27A  of the Securities Act of 1933, and Section 21E of the
Exchange Act of 1934, do not apply to issuer s of penny stock.  Please remove the
references to these sections.

John S. Kovach
SRKP 7, Inc.
October 4, 2006 Page 4
Management’s Discussion and Analysis, page 24

Critical Accounting Policies – Stock-Based Compensation, page 25

15. We note in the last sentence of this secti on that you did not have any stock options
or warrants issued or outstanding at December 31, 2005.  This discussion should be expanded to include the stock options  granted on June 30, 2006 as disclosed in
Note 3 on page F-13 of the interim financ ial statements and the impact of SFAS
123(R) on these issuances.

Results of Operations, page 26

16. Since Lixte has not generated revenue dur ing the periods pres ented, discussion of
your plan of operation should be provided.  Please revise the filing to comply with Item 303(a) of Regulation S-B.

Going Concern, page 26

17. Please discuss your disclosed need for $2.3 million.  We note your reference to a wet lab on page 6.  It is unclear why this  wet lab is necessary in the short term
given your current operations.  Als o, will you need additional property or
employees to operate the lab?  Are these costs included in the $2.3 million estimate?

Business, page 28

Our company, page 28

18. Please state the date of your incorporati on.   If you were organized in connection
with affiliated companies, please describe those affiliations.  Also, describe any change in control.

John S. Kovach
SRKP 7, Inc.
October 4, 2006 Page 5
Intellectual Property, page 29

19. Please disclose when the negotiations me ntioned in the third sentence began.
Also disclose:
• the status of the negotiations;
• the principal hurdles that remain befo re an agreement can be reached; and
• the scope of your rights to the intell ectual property if no agreement can be
reached.
20. With a view toward disclosure, please te ll us how Dr. Kovach was involved in
developing the intellectual property to th e extent that he is co-owner.

Access to Clinical Materials, page 29

21. Please expand your disclosure that “permi ssion has been obtained” to identify the
entity who granted permission and the scope of such permission.

22. We note your disclosure that you are nego tiating an agreement to receive tissue
and blood samples from the Institute of Pathology in Germany.  Please revise to address how you currently obtain such samples.

Research and Development, page 31

Tissue Acquisition, page 31

23. Expand your disclosure to clarify your obligations and potential liability, if any, under the regulatory requirements of th e Office of Protection of Research
Subjects in the United States.

Product Development, page 33

24. Please expand your disclosure to state at what stage your business activities will
become subject to FDA regulation.

John S. Kovach
SRKP 7, Inc.
October 4, 2006 Page 6
Competition, page 33

25. Please clarify whether any competitors have developed or are investigating biomarkers for the same cancer that you are studying.

Properties, page 34

26. Please clarify the nature of your  facility.  Is this a leased  office devoted solely to
your business in a commercial office building with multiple unrelated tenants?

Government Regulation, page 34

27. Please clarify how each cited regulation affects your business. Also clarify
whether you are in compliance.

Management, page 35

28. We note the statement on page 37 that your director, Dr. Philip Palmedo, has
served as a consultant to the government of  Sudan.  Please advise us of the nature
and extent of the consultancy.  Tell us whether Dr. Palmedo has served as a consultant to the government of Sudan during the period he has served as your
director, and whether he con tinues to serve as a consu ltant to the government of
Sudan.  Please also describe your past, current and anticipat ed contacts with
Sudan, if any, whether through subsidiaries, affiliates or other direct or indirect
arrangements.  We may have further comment.
29. Please clarify when Dr. Palmedo joined the board.

Scientific Advisory Committee, page 37

30. Please describe the role of the committ ee.  For example, how often does the
committee meet?  On what matters have th ey deliberated and advised you? When
did each member join the committee?

John S. Kovach
SRKP 7, Inc.
October 4, 2006 Page 7
31. If the committee members serve a management  role, please provide full disclosure
regarding their background.  See, for example, Regulation S-B Item 401(b).  If the
committee does not serve in a management role, please tell us why you have identified the committee in the management section of your prospectus.

Executive Compensation, page 38

32. Please provide disclosure for each person who served as your CEO or acted in a similar capacity during the last completed fiscal year.  See Regulation S-B Item 402 (a)(2)(i).  Also, include a row for each  such person in your table disclosing
beneficial ownershi p of your stock.

Director Compensation, page 39

33. Please revise to disclose when your di rectors and members of the Scientific
Advisory Committee will receive the options.

Certain Relationships and Relate d Party Transactions, page 40

34. We note your disclosure that most office se rvices are provided by the president.
Revise to disclose the name of the indi vidual who serves in this capacity.
35. Tell us why you have not provided disclosu re under Item 404(a) of Regulation S-
B for the commission and fee paid to WestPark Capital, Inc. for its services as
placement agent in connection with your rece nt private placements.  We note that
at the time of the transaction, it appear s your president, Mr. Rappaport, was also
CEO of WestPark Capital.
36. Please tell us why you have not described in this section the stockholder advances
mentioned on pages 27 and F-2.
37. Please provide the disclosure  required by Item 404(d) of Regulation S-B.

Description of Securities, page 40

38. Please disclose when you split your securiti es as mentioned at the bottom of page
2. Also, tell us when shareholders approved the split.

John S. Kovach
SRKP 7, Inc.
October 4, 2006 Page 8
39. Please quantify the amounts required by Regulation S-B Item 201(a)(2).

Selling Stockholders, page 41

40. Please revise the selling stockholder ta ble to identify the individuals who
beneficially own the shares held by the entities named in the table.
41. Please tell us whether any of the selli ng shareholders are broker-dealers or
affiliates of broker-dealers.
42. Please disclose when each selling share holder acquired the offered shares and the
consideration paid for those shares.

Financial Statements, page F-1

43. Please update your financial statements, as necessary, to comply with Item 310(g)
of Regulation S-B.
44. Please tell us your basis for incorporati ng by reference the information from your
Form 8-K as disclosed on page F-7.

Interim Financial Statements for the period ended June 30, 2006

Condensed Consolidated Balance Sheet, page F-2

45. There is no distinction made herein of which liability items are current or non-
current.  Based on the disclosure in MD &A about the amount of working capital
at June 30, 2006, it appears that the resear ch and development contract liability
represents a current liability at that da te.  Please revise your balance sheet to
classify liabilities as either current or long-term.

Condensed Consolidated Statement of Stoc kholders’ Equity (Deficiency), page F-4

46. We note that the 4,005,177 shares issued in  connection with the reverse merger
transaction represent those held by the Company’s stockholders immediately prior
to the share exchange and the value assigned to thes e shares ($62,500) was based

John S. Kovach
SRKP 7, Inc.
October 4, 2006 Page 9
on the cash acquired in the transaction.  According to Form 10-QSB for the
quarter ended March 31, 2006, the Co mpany only had $3,000 in cash and
negative working capital of approximate ly $10,000.  Please provide us with a
summary calculation of how the amount of cash acquired on June 30, 2006 was determined and tell us from what source it was derived.  Also, tell us why you
believe your accounting entry for the re verse merger was appropriate and
compliant with GAAP.  Finally, revise the filing as necessary based on our
comment.

Note 3. Share Exchange Agreement and Private Placement, page F-11

Private Placement, page F-12

47. Please disclose the terms of any registrati on rights agreements.  We note that there
was no financial penalty associated with these registration rights.  Please tell us
the accounting implications of the rights.   Your response should address how
EITF 05-04 impacts your conclusions.

Note 4. Related Party Transactions, page F-13

48. Please disclose the terms and conditions of the non-interest bearing advances
made by Lixte’s founding stockholder.

Note 6. Commitments and Contingencies, page F-14

49. We note that on March 22, 2006 you entered into a contract (CRADA) with the
U.S. Department of Health and Human Services whereupon you agreed to provide
funds totaling $400,000 over a two-year term .  We further note that this was
recorded as a liability with the related amount of su ch contract recorded as
“deferred research and development costs”  (i.e., an asset).  Please tell us why you
believe you have correctly accounted for this agreement.  Also, tell us how the latter satisfies the definition of an asset as described in paragraph 25 of CON6 and
why you believe it was appropriate to reco rd it as a fixed asset.  Reference your
response to the guidance in CON6 or other applicable authoritative accounting
literature.  Also, please include a copy of  the agreement as an exhibit to the filing.

John S. Kovach
SRKP 7, Inc.
October 4, 2006 Page 10
Recent Sales of Unregister ed Securities, page II-2

50. Please provide the disclosure requir ed by Regulation S-B Item 701 for all
securities sold during the past three  years without registra tion under the Securities
Act.

51. Please disclose the facts relied upon to make the cited exemption from registration available

Item 28. Undertakings, page II-4

52. Please include the undertakings requ ired by item 512(a)(4) and 512(g) of
Regulation S-B.  Refer to Rule 424(b)(3) and Rule 430C(d).

Item 27.  Exhibits

53. Please tell us why you have not filed the Cooperative Research and Development Agreement as an exhibit.

Exhibit 23.2

54. Please provide an updated consent fro m your independent accountant in any
amendment.

Signatures

55. Please indicate below the second paragr aph required on the Signatures page who
is signing the document in the capacity of principal financial o fficer and controller
or principal accounting officer .  See “Instructions for si gnatures” at the end of
Form SB-2.

As appropriate, please amend your regist ration statement in response to these
comments.  You may wish to provide us with marked copies of the amendment to

John S. Kovach
SRKP 7, Inc.
October 4, 2006 Page 11
expedite our review.  Please furnish a cove r lett