SecProbe.io

December 15, 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.
Amendment No. 1 to Form SB-2
Filed December 1, 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.
We welcome any questions you may have  about our comments or any other
aspect of our review.  Feel fr ee to call us at the telephone numbe rs listed at the end of this
letter.

Amendment No. 1 to Form SB-2

Prospectus Cover
1. We note your response to comment 1 in our letter to you dated October 4, 2006.
Your revised disclosure does not disc lose the price at which your selling
shareholders will sell their securities.  Ther efore, we reissue the first sentence of
comment 1.

The Offering, page 2
2. Please ensure that the information disclose d here matches the number of securities
included in the fee table and the numbers  in your table of selling stockholders.

John S. Kovach
SRKP 7, Inc.
December 15, 2006 Page 2
Risk Factors, page 5

If our products were derived from tissue or other samples from a patient…, page 13
3. We note your response to comment 9.  Howe ver, that comment sought disclosure
in your prospectus.  Please revise your document to disclose when the
negotiations began and update any changes in  the status of the negotiations.  If the
negotiations are completed, please file the resulting agreement as an exhibit and disclose in an appropriate section of your document the material terms, including
duration and terminati on provisions.
Management’s Discussion and Analysis, page 24

Results of Operations, page 26
4. Please refer to prior comment 16.  We note your expanded disclosure included
under “Going Concern” on page 27 about the additional funding of approximately
$2.3 million to establish a wet laboratory.  However, to adequately address all of
the requirements in Item 303(a) of Regul ation S-B, add a separate section to
describe in detail your plan of opera tions for the next twelve months.

Research and Development Costs, page 26
5. We note in the first sentence of the second paragraph of this s ection that you state
the current amount due pursuant to the CRA DA “was recorded as a liability”.
Based on your response to prior comment 49 and revisions made on the balance sheet as of September 30, 2006, please tell us where the referenced liability is
presented in your September 30, 2006 bala nce sheet or revise the filing as
necessary based on our concern.

Intellectual Property, page 29
6. Please file and disclose the material  terms of the December 2006 agreement
mentioned in your response to prior comment 19.
7. Please name the patent counsel mentione d in the fourth paragraph. Also, file
counsel’s consent as an exhi bit that expressly states that counsel consents to your
summarization of its opinion in the registration statement.

John S. Kovach
SRKP 7, Inc.
December 15, 2006 Page 3
Government Regulation, page 34
8. We note your response to prior comment 24.  Please disclose the nature of the
FDA regulation to which you will be subjec t when you “begin to pursue clinical
trials.”

Management, page 35
9. We note your response to prior comment 28 and the description of Dr. Palmedo’s
work for the Government of Sudan in 1980.  However, you did not address whether you have other past, current or anticipated contacts with Sudan, through
subsidiaries, affiliates or other direct or  indirect arrangements.  If you have no
past, current or anticipate d contacts with Sudan in addition to Dr. Palmedo’s
contacts described in your Decembe r 1, 2006 letter, please state so.

Scientific Advisory Committee, page 37
10. We note your revised disclosure in respons e to comment 31.  It is not clear why
you have identified the committee in the ma nagement section of your prospectus
given your response that the committee does not serve any management function.  Please move this disclosure to an ap propriate section of your prospectus.

Security Ownership, page 39
11. Please provide the disclosure requested in the last sentence of prior comment 32.

General, page 40
12. Please tell us why your disclosure in  response to prior comment 39 does not
address the warrants mentioned in the fourth paragraph on page 40.

Selling Stockholders, page 41
13. We note your response to comment 40.  Ho wever, it does not appear that the
selling stockholder table has been revise d to address the comment.  We reissue
comment 40.

John S. Kovach
SRKP 7, Inc.
December 15, 2006 Page 4
Financial Statements, page F-1
14. Please expand your response to prior comme nt 44 to cite with specificity the
authority that permits you to incorpor ate a Form 8-K into a Form SB-2.

Note 6. Commitments and Contingencies, page F-21
15. Please refer to prior comment 49.  We not e the revisions made on the balance
sheet as of September 30, 2006 and see you now present an asset labelled “advances on research and development contract services, net” of $100,000.  We
further note that through the end of th is period you have made aggregate
payments of $200,000 and recorded resear ch and development expenses of
$100,100 in connection with the CRADA agreement.   It is still not clear to us why
the $100,000 “advance” satisfies the definition of an asset as described in paragraph 25 of CON6.  Please tell us and revise the notes to the financial
statements to specifically indicate why you believe it is appropria te to record the
referenced amount as an asset.   Altern atively, revise the filing as necessary to
expense the amount in question.  Your response should address whether you have
the right to receive a refund or return of  amounts paid (and presented as an asset)
under the agreement – in this regard Ar ticle 10.3 of the agreement appears to
indicate no such right exists.   Note the guidance at SFAS 2 and the concepts
outlined in FIN 4.  Finally, we note you included a copy of the agreement in Exhibit 10.1.  Please revise the filing to  attach Appendix B, which includes the
payment schedule as indicated in Articl e 5.3 of the CRADA, to this exhibit.

Recent Sales of Unregister ed Securities, page II-2
16. With a view toward disclosure, please tell  us the date and amount of the reverse
split mentioned in the first sentence.  Also tell us when shareholders approved the
split.
17. Please provide us a table that clearly reconciles the information in this section
with the number of your outstanding shares.

Undertakings, page II-4
18. We note your revised disclosure and res ponse to comment 52.  It does not appear
that you have provided the 512(a)(4) undertakings.  Please provide the
undertakings required by Item 512(a)(4) of Regulation S-B.

John S. Kovach
SRKP 7, Inc.
December 15, 2006 Page 5
Exhibits
19. We note your response to prior comment 53.  Please file complete exhibits with
all attachments.

Signatures
20. We reissue prior comment 55 in part.  Please clarify below the second paragraph
required on the Signatures page who is signing the document in the capacity of
controller or principal accounting officer.
21. Please clarify whether a majority of your board of directors signed the document.

Form 10-QSB filed November 14, 2006

Item 3.  Controls and Procedures, page 19
22. We note that your disclosure under the caption “Changes in Internal Controls”
refers only to internal controls.  In future filings, if you are referring to the
information in Item 308(c) of Regulation S- B, please revise to  state clearly that
you are referring to internal controls over financial reporting.

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 expedite our review.  Please furnish a cove r 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 amendmen t 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 in formation required under
the Securities Act of 1933 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.

We will consider a written request for acceleration of the effective date of the
registration statement as conf irmation of the fact that t hose requesting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te to the proposed public offering of the

John S. Kovach
SRKP 7, Inc.
December 15, 2006 Page 6
securities specified in the above registration statement.  We will act  on the request and,
pursuant to delegated authority, grant acce leration of the effective date.
We direct your attention to Rules 46 0 and 461 regarding requesting acceleration
of a registration statement.  Please allow ad equate time after the filing of any amendment
for further review before submitting a request for acceleration.  Please provide this request at least two business days in a dvance of the requested effective date.

You may contact David Bu rton at (202) 551-3626 or Jay Webb at (202) 551-3603
if you have questions regarding comments on the financial statements and related
matters.  Please contact Eduardo Aleman at (202) 551-3646 or me at (202) 551-3617 with
any other questions.

     S i n c e r e l y ,

     R u s s e l l  M a n c u s o
Branch Chief

cc(via facsimile):  David Ficksman – Troy & Gould, P.C.