Med BioGene Inc.

701 West Georgia Street, Suite 1500

Vancouver, British Columbia V7Y 1C6

Canada

February 2, 2012

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Re:	Med BioGene Inc. File No. 333-164050
	Application for Withdrawal on Form RW pursuant to Rule 477 of the Securities Act of 1933 of the Registration Statement on Form F-1

Ladies and Gentlemen:

Pursuant to Rule 477 (“Rule 477”) promulgated under the Securities Act of 1933, as amended (the “Securities Act”), Med BioGene Inc. (the “Registrant”) hereby requests that the U.S. Securities and Exchange Commission (the “Commission”) consent to the withdrawal of the Company’s Registration Statement on Form F-1 (File No. 333-164050) as filed with the Commission on June 22, 2010, together with all exhibits thereto (the “Registration Statement”).

The Registrant is requesting the withdrawal of the Registration Statement because the Registrant has decided not to pursue an initial public offering of its securities at this time due to the availability of other opportunities that the Board of Directors of the Company deemed to be in the best interests of the Company and its shareholders. The Registration Statement was not declared effective by the Commission and none of the Registrant’s securities were sold pursuant to the Registration Statement. The Registrant believes that the withdrawal of the Registration Statement is consistent with the public interest and the protection of investors, as contemplated by Rule 477.

The Registrant acknowledges that no refund will be made for fees paid to the Commission in connection with the filing of the Registration Statement. However, the Registrant requests, in accordance with Rule 457(p) under the Act, that all fees paid to the Commission in connection with the filing of the Registration Statement be credited to the Registrant’s account to be offset against the filing fee for any future registration statement or registration statements of the Registrant or an affiliate.

It is our understanding that this application for withdrawal of the Registration Statement will be deemed granted as of the date that it is filed with the Commission unless, within fifteen days after such date, the Registrant receives notice from the Commission that this application will not be granted.

February 2, 2012

Page 2

If you have any questions regarding the foregoing application for withdrawal, please contact the Company’s counsel, Kevin K. Rooney, Esq. of Sheppard Mullin Richter & Hampton, LLP, at (650) 815-2625.

Sincerely,
Med BioGene Inc.
By:	/s/ Erinn Broshko
	Erinn Broshko
	Chief Executive Officer