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Published on May 14, 2007
File
No. 2392-1
May
14,
2007
Via
Fax (202) 772-9218 and Edgar
Mr. Russell
Mancuso
Branch
Chief
United
States Securities and Exchange Commission
Office
of
Emerging Growth Companies
Mail
Stop
3561
100
F
Street, N.E.
Washington,
D.C. 20549
|
Re:
|
Lixte
Biotechnology Holdings, Inc.
Amendment
No. 5 to Form SB-2
Filed
May 5, 2007
File
No. 333-137208
|
Dear
Mr. Mancuso:
Lixte
Biotechnology Holdings, Inc. (the “Company”) hereby represents that there are no
material changes in the financial conditions and results of operations from
the
financial statements as previously reported in Amendment No. 5 to the
Registration Statement on Form SB-2.
|
Very
truly yours,
|
|
|
/s/
John Kovach, M.D.
|
|
|
Chief
Executive Officer
|
| cc: |
David
Ficksman
|
Eduardo
Aleman