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Via Facsimile and U.S. Mail
Mail Stop 6010


July 1, 2005


Mr. G. Dale Garlow
Chief Executive Officer
Vyrex Corporation
2159 Avenida de la Playa
La Jolla, CA  92037


Re:	Vyrex Corporation
	Form 10-KSB for the Fiscal Year Ended December 31, 2004
	Filed March 29, 2005
	File No. 000-27866


Dear Mr. Garlow:

	We have limited our review to only your financial statements
and
related disclosures and do not intend to expand our review to
other
portions of your document.  In our comments, we ask you to provide
us
with supplemental information so we may better understand your
disclosure.  Please be as detailed as necessary in your
explanation.
After reviewing this information, we may raise additional
comments.

	Please understand that the purpose of our review 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Financial Statements, page F-1

Report of Independent Registered Public Accounting Firm, page F-2

1. As your auditor has relied on the reports of other auditors,
please provide us the reports of those other auditors, as they
apparently should have been included in your filing. Please refer
to
Rule 2-05 of Regulation S-X.


Notes to Financial Statements, page F-7

2.  Summary of Significant Accounting Policies, page F-9

2. Please tell us how you have accounted for the salaries not
being
received by your current employees and how your accounting
complies
with GAAP. Tell us whether and to what extent you have a liability
for these salaries and where it is recorded in your financial
statements.

4.  License and Collaboration Agreements, page F-11

3. Please tell us how you recognized revenue for all amounts
received
to date for the license agreement and how your accounting complies
with SAB 104 particularly as it relates to non-refundable amounts.
Also include in your response the duration of and your obligations
under the license agreement and why you did not defer income.

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provide the
requested information.  Detailed letters greatly facilitate our
review.  Please file your letter on EDGAR under the form type
label
CORRESP.  Please understand that we may have additional comments
after reviewing your 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
filings include all information required under the Securities
Exchange Act of 1934 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.


	In connection with responding to our comments, please
provide,
in your letter, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* 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
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Keira Ino, Staff Accountant, at (202) 551-
3659
or Oscar Young, Senior Staff Accountant, at (202) 551-3622 if you
have questions regarding comments on the financial statements and
related matters.  Please contact me at (202) 551-3679 with any
other
questions.


Sincerely,



Jim B. Rosenberg
Senior Assistant Chief
Accountant
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G. Dale Garlow
Vyrex Coporation
July 1, 2005
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