SPECTRASCIENCE(TM), Inc.                                   [LOGO] SPECTRASCIENCE
3650 Annapolis Lane, Suite 101
Minneapolis, Minnesota 55447-5434 USA
Tel: 612 509 9999   Fax: 612 509 9805

July 28, 1999

Michael K. Ferraro
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

Re:   SPECTRASCIENCE, Inc.
      Registration Statement on Form SB-2
      SEC File No. 333-59395

Dear Mr. Ferraro:

      On behalf of SPECTRASCIENCE, Inc. (the "Company"), we hereby apply to
withdraw the Company's Registration Statement on Form SB-2 (the "Registration
Statement"). The Registration Statement has not been declared effective. The
Company is withdrawing the Registration Statement because market conditions have
not been conducive to an offering of the Company's Common Stock. No securities
have been offered or sold pursuant to the Registration Statement.

      With regard to the open issues raised by the Commission in its letter
dated October 20, 1998, the Company has the following responses:

      1.    The Company does not believe that the loss of Portlyn Corporation as
            a supplier would have a material adverse effect on the Company.
      2.    No additional disclosure is required since the Registration
            Statement is being withdrawn.
      3.    The Company filed the initial MIT License Agreement as Exhibit 10,11
            to its Quarterly Report on Form 10-Q for the quarter ended March 31,
            1990. The Company represents that it will file any amendments to the
            MIT License Agreement in its Quarterly Report on Form 10-Q for the
            quarter ended June 30, 1999.

      If you have any questions regarding this request, please feel free to
contact the undersigned at (612) 509-9999, ext. 208, or Theodore C. Cadwell, Jr.
of Dorsey & Whitney LLP at (612) 343-2160. Thank you.

Sincerely,



/s/ CHESTER E. SIEVERT, JR.
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Chester E. Sievert, Jr.
President and Chief Executive Officer