SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

  Mail Stop 3010

 May 3, 2010  Dr. Steve N. Slilaty Chief Executive Officer Sunshine Biopharma, Inc. 6100 Royalmount Avenue Montreal, Quebec, Canada H4P 2R2

Re: Sunshine Biopharma, Inc.
 Schedule 14C
Filed April 21, 2010
 File No. 000-52898

Dear Dr. Slilaty:

We have conducted a limited review of  your filing and have the following
comments.  Where indicated, we think you s hould revise your document in response to
these comments.  If you disagree, we will consider your explanation as to why our
comments are inapplicable or a revision is  unnecessary.  Please be as detailed as
necessary in your explanation.  In our comments, we may ask you to provide us with
additional information so we may better understand your disclosu re.  After reviewing this
information, we may or may not 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.
 General

1. We note the Form 8-K filed on Oct ober 20, 2009, which indicates that you
executed an agreement to acquire Sunshi ne Biopharma, Inc. in exchange for
21,962,000 shares of your common stock and 850,000 shares of convertible
preferred stock.  Please expl ain to us whether share holder approval was required
for the merger or the issuance of stock to Sunshine Biopharma, Inc.  Also, tell us whether shareholder approval was required for your name change to Sunshine
Biopharma, Inc.  If shareholder approval  was required for one or more of the

Dr. Steve N. Slilaty
Sunshine Biopharma, Inc. May 3, 2010 Page 2

above events, please describe to us how the solicitation of shareholder approval
complied with the proxy rules.
2. The Form 8-K filed on October 20, 2009 di scloses disclose that your former
Board of Directors approved a spin-o ff of your wholly owned subsidiary,
Mountain West Beverage, Inc., to your sh areholders of record as of October 14,
2009.  Please provide us your analysis of why it was appropriate  to conduct this
spin-off without registration under the S ecurities Act.  Please see Staff Legal
Bulletin No. 4, which is av ailable on our website at
http://www.sec.gov/interps/ legal/slbcf4.txt.

Purpose and Effect of the Increas e in Authorized Capitalization
3. The third paragraph under this  heading states that the Board of Directors expects
to undertake a private equity offering of your  securities in the near future and that
management is considering entering into certain consulting agreements that may
require the issuance of common stock as consideration for the services to be
performed.  Please provide additional info rmation regarding the private equity
offering and issuance of common stock as c onsideration for cons ulting services as
called for by Item 11(c) of Schedule 14A.  Additionally, please furnish the
financial information required by Item 13( a) of Schedule 14A or tell us why you
do not believe Item 13(a) information is required to be disclosed.
As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response.  You may wish to
provide us with marked copies of the amendm ent to expedite our review.  Please furnish
a cover letter with your amendment that keys your responses to our comments and
provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.    We urge all persons who are responsi ble for the accuracy an d 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 comments, please provide, in writing, 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 disclosu re in response to staff comments do

Dr. Steve N. Slilaty
Sunshine Biopharma, Inc. May 3, 2010 Page 3

not foreclose the Commission from ta king any action with respect to the
filing; and

• the company may not assert sta ff comments as a defense in any
proceeding initiated by the Commissi on 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.     Please contact Phil Rothenberg at (202)  551-3466 or me at (202) 551-3785 with
any questions.
Sincerely,
    Karen J. Garnett
Assistant Director