SecProbe.io

February 6, 2012
 VIA E-MAIL

Mr. Camille Sebaaly Chief Financial Officer Sunshine Biopharma, Inc. 2015 Peel Street, 5
th Floor
Montreal, Quebec, Canada H3A 1T8

Re: Sunshine Biopharma, Inc.
 Item 4.01 Form 8-K
Filed on February 3, 2012
 File No. 000-52898

Dear Mr. Camille Sebaaly:
 We have reviewed your filing and have the following comment. In our comment, we may
ask you to provide us with information so we may better understa nd your disclosures.
 Please respond to this letter within fi ve business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response. If you do not believe our comment app lies to your facts and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have additional comments.
 FORM 8-K FILED ON FEBRUARY 3, 2012

1. We note that in connection with the audit of your financial statements  as of and for the
fiscal years ended September 30, 2009, a nd December 31, 2009 and 2010, there were no
disagreements with RRC on any matter of accoun ting principles or practices, financial
statement disclosure, or auditing scope of procedures, which disagreements, if not
resolved to the satisfaction of RRC, woul d have caused them to make reference in
connection with its reports to the subject matter of the disagr eements.  Please amend your
8-K to also cover the subsequent  interim period from the date of the last audited financial
statements up until the date of dismissal of RRC.   See Item 304(a)(1)(iv) of Regulation
S-K.   Include an updated letter from RRC addressing your revised disclosure as an
exhibit to your Form 8-K/A.

Mr. Camille Sebaaly Sunshine Biopharma, Inc. February 6, 2012 Page 2

 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. 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.
 In responding to our comment, please provide a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.

You may contact me at (202) 551 – 3468 if you have any questions re garding our comment.

                                                                     Sincerely,
   /s/ Wilson K. Lee

       Wilson K. Lee
                Staff Accountant