SecProbe.io

August 18, 2011
 Via Fax

Elliot Maza Chief Executive Officer and CFO BioZone Pharmaceuticals, Inc 4400 Biscayne Boulevard Miami, Florida 33137
Re: BioZone Pharmaceuticals, Inc
 Item 4.01 Form 8-K
Filed August 17, 2011 File No. 333-146182

Dear Mr. Maza:
 We have reviewed your filing and have the following comment.  In our comment, we
may ask you to provide us with informati on so we may better understand your disclosure.
 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 applies to your fact s 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 these comments, we ma y have additional comments.

Form 8-K

Item 4.01. Changes in and Disagreements with Accountants on Accounting and Financial Disclosure.

Dismissal of previous independent registered public accounting firm

1. We note that you dismissed Q Accountancy Corporation effective August 11, 2011.
However, it appears that the representations related to your predecessor and successor auditor
only cover the period from March 30, 2010 to Ju ly 31, 2011.  Please amend your filing to
extend the period covered by these representations to the date of dismissal or explain to us
why you are unable to make those representations.  Include an updated letter from your
former auditor addressing your revised disclo sure as an exhibit to your Form 8-K/A.
Reference is made to Item 304(a)(1)(iv) of Regulation S-K.

Elliot Maza BioZone Pharmaceuticals, Inc August 18, 2011 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 comments, please provi de 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 the undersigned at  (202)551-3438 if you have questions.

Sincerely,
   /s/ Robert F Telewicz Jr.
Robert F Telewicz Jr.
Staff Accountant