-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, WBXWHqTrrnhEnopokO0Au+5xdgby/MycIBU/Wt4gRAZhdYGPSbKX3g+qCtpHyezc 6XZo1MEhcBWHggwwX9eLZw== 0001095435-05-000010.txt : 20060829 0001095435-05-000010.hdr.sgml : 20060829 20050511170614 ACCESSION NUMBER: 0001095435-05-000010 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050511 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BONTAN CORP INC CENTRAL INDEX KEY: 0001095435 STANDARD INDUSTRIAL CLASSIFICATION: CRUDE PETROLEUM & NATURAL GAS [1311] IRS NUMBER: 000000000 FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 47 AVENUE ROAD STREET 2: SUITE 200 CITY: TORONTO STATE: A6 ZIP: M5R 2G3 BUSINESS PHONE: 416-929-1806 MAIL ADDRESS: STREET 1: 47 AVENUE ROAD STREET 2: SUITE 200 CITY: TORONTO STATE: A6 ZIP: M5R 2G3 FORMER COMPANY: FORMER CONFORMED NAME: DEALCHECK COM INC DATE OF NAME CHANGE: 19990921 CORRESP 1 filename1.htm Blank document-portrait



Messerli & Kramer P.A.

150 South Fifth Street, Suite 1800

Minneapolis, Minnesota  55402




Via EDGAR


May 11, 2005


U.S. Securities and Exchange Commission

450 Fifth Street N.W.

Washington, D.C.  20549-0405



Re:

Bontan Corporation (the "Company")

Amendment No. 1 to Registration Statement on Form F-3

SEC File No. 333-123533


Amendment No. 1 to Form 20-F for the year ended March 31, 2004



Ladies and Gentlemen:


With this letter, we are filing Amendment No. 1 to the above Registration Statement.  By separate letter, the Company is requesting acceleration of the effectiveness of the Registration Statement to 3:30 p.m., Eastern Time, on Friday, May, 13, 2005.


This letter is in response to the Staff’s comment letter dated April 22, 2005.  Item numbers below correspond to the Item numbers in the Staff’s comment letter.


1.

We have amended the table of selling shareholders to include natural persons who exercise voting and/or dispostive powers with respect to the securities to be offered for resale by each of the selling shareholders in the latest filing.


2.

Supplementally, we advise the Staff that no selling shareholder is a registered-broker dealer or affiliate of a registered broker-dealer in the United States.  However, two selling shareholders are registered broker-dealers under Quebec laws.


3.

On May 10, 2005, the Company filed Amendment No. 1 to its annual report on Form 20-F for the year ended March 31, 2004, making the changes set forth in comments 3, 4, 5 and 6 of the Staff's comment letter dated April 22, 2005.




We request that the Staff expedite review of this filing.  As indicated above, we are separately requesting acceleration of the Registration Statement’s effectiveness.


Please contact the undersigned regarding this filing as Jeff Robbins is out of the country. The undersigned's number is 612-672-3765.  Thank you for your prompt attention to our filing.


Very truly yours,



/s/ Pamela A. Curran   


Pamela A. Curran

Messerli & Kramer P.A.

150 South Fifth Street, Suite 1800

Minneapolis MN 55402

612 672 3765 (direct)

pcurran@mandklaw.com





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