Mr. Oscar M. Young Jr.
U.S. Securities and Exchange Commission
450 Fifth St., N.W.
Washington, D.C.  20549

Re:      Amarillo Biosciences, Inc. ("Amarillo Biosciences")
         Form 8-K, Filed August   25, 2004
         File No.: 0-20791

Dear Mr. Young:

      The following  are our  responses to your comment  letter dated August 24,
2004.  Our  responses are numbered to  correspond  with the numbered  paragraphs
included in your comment letter.

General

1.    We have provided in writing that Amarillo Biosciences acknowledges that:

            Amarillo Biosciences is responsible for the adequacy and accuracy of
            the disclosure in the filing;

            The staff  comments  or changes to  disclosure  in response to staff
            comments in the filings by the staff do not foreclose the Commission
            from taking any action with respect to the filing; and

            Amarillo  Biosciences  may not assert staff comments as a defense in
            any proceedings  initiated by the Commission or any person under the
            federal securities laws of the United States of America.

            2. We have  revised  the filing to discuss  the former  accountant's
            report for each of the past two years.

            3. We have  revised the filing  address  the two most recent  fiscal
            years and  subsequent  interim  period  through the dismissal of the
            former accountant and have deleted "in connection with the audit"



            4. We have revised the filing to delete the  reference to the former
            accountant in providing  disclosures  required by Item  304(a)(2) of
            Regulation S-B.

            5. We have  filed  an  updated  letter  from the  former  accountant
            covering the revised disclosures.

                                                     Very truly yours,

                                                     Amarillo Biosciences, Inc.

                                                     Joseph M. Cummins, DVM, PhD
                                                     Chief Executive Officer and
                                                     Chief Financial Officer