Via Facsimile and U.S. Mail
Mail Stop 6010


June 17, 2005


Mr. Brian Lenz
Chief Financial Officer and Secretary
VioQuest Pharmaceuticals, Inc.
7 Deer Park Drive, Suite E
Princeton Corporate Plaza
Monmouth Junction, NJ  08852

Re:	VioQuest Pharmaceuticals, Inc.
	Form 10-KSB for the fiscal year ended December 31, 2004
      Filed on March 31, 2005
	File No. 000-16686

Dear Mr. Lenz:

      We have reviewed your response letter dated June 6, 2005 to
our
comment letter dated April 29, 2005 and have the following
comments.
Where indicated, we think you should revise your Form 10-KSB for
the
year ended December 31, 2004 and your Form 10-QSB for the quarter
ended March 31, 2005 to include the revisions you have proposed in
the draft Form 10-KSB/A for the year ended December 31, 2004 that
you
provided us and 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 detailed as necessary
in
your explanation.  In some of our comments, we may ask you to
provide
us with information so we may better understand your disclosure.
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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.



Item 6. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations or Plan of Operations, page 20

Results of Operations - Years ended December 31, 2004 vs. 2003,
page
21

1. Please refer to your response to our prior comment number one.
In
addition to the proposed qualitative discussion you provided in
your
draft Form 10-KSB/A, please quantify the impacts of the
qualitative
factors disclosed.  Refer to Item 303(b)(1) of Regulation S-B.

2. Please refer to your response to our prior comment number
three.
Please provide to us your analysis under SFAS 2 of why these costs
are research and development costs.

Critical Accounting Policies and Estimates, page 24

Revenue Recognition, page 24

3. We note your proposed disclosure in your draft Form 10-KSB/A as
a
result of our comment number six.  Please expand your disclosure
to
address the judgments and estimates inherent to your determination
of
net revenue. Additionally, please clarify for us, and in the
document
whether those estimates relate to sales returns, discounts or
allowances. If your estimates do relate to those items that reduce
your net revenue, please revise your disclosures to address the
information we requested in our initial comment.

Consolidated Statements of Operations, page F-4

4. Refer to your responses to comments eight and nine.  We believe
that your proposed revisions should be made in the amendment to
your
December 31, 2004 Form 10-KSB.

Note 5.  Rights to Intellectual Property - F-14

5. Please refer to your response to our prior comment number 11.
Please include your proposed disclosures in an amendment to your
December 31, 2004 10-KSB.  Specifically address in this policy how
the outcome of defending your patents impacts the amounts
capitalized.  Also include a discussion of the specific items that
resulted in the increases in each the current period.





      As appropriate, please amend your filings and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment 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 cover letters
greatly
facilitate our review.  You should file the letter on EDGAR under
the
form type label CORRESP. Please understand that we may have
additional comments after reviewing your amendment 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 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.

	As requested in our prior comment letter, please provide, in
your response letter, 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 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 Tabatha Akins, Senior Accountant, at 202-
551-
3658, or James Atkinson, Accounting Branch Chief, at 202-551-3674
if
you have questions regarding the comments. In this regard, do not
hesitate to contact me, at (202) 551-3679.

							Sincerely,


							Jim B. Rosenberg
						Senior Assistant Chief Accountant
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Mr. Brian Lenz
VioQuest Pharmaceuticals
June 17, 2005
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