November 30, 2004


Mr. Jeffrey Riedler, Esq. 
Mail Stop 3-09
United States Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20548

Re:      GeneThera, Inc.
         Registration Statement on Form SB-2
         File No. 333-118937

Dear Mr. Riedler,

Pursuant to Rule 461 under the Securities Act of 1933, as amended, GeneThera,
Inc. requests that the effective date of the Registration Statement be
accelerated so that the Registration Statement may become effective by 1:00 p.m.
on December 1, 2004 or as soon thereafter as practicable.

GeneThera acknowledges that:

      o     Should the Commission or the staff, acting pursuant to delegated
            authority, declare the filing effective, it does not foreclose the
            Commission from taking any action with respect to the filing;

      o     The action of the Commission or the staff, acting pursuant to
            delegated authority, in declaring the filing effective, does not
            relieve the Company from its full responsibility for the adequacy
            and accuracy of the disclosure in the filing; and

      o     The Company may not assert this action as defense in any proceeding
            initiated by the Commission or any person under the federal
            securities laws of the United States.

Sincerely,

Steven M. Grubner
Chief Financial Officer