August 18, 2010

United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Mr. Jeffrey Riedler, Assistant Director

Biovail Corporation
Registration Statement on Form S-4 (File No. 333-168254)

Dear Mr. Riedler:

          Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), Biovail Corporation (the “Company”) hereby requests that the effective date of the above referenced Registration Statement (the “Registration Statement”) be accelerated by the Securities and Exchange Commission (the “Commission”) so that the Registration Statement, as then amended, becomes effective under the Securities Act by 5:30 p.m., eastern time, on August 20, 2010, or as soon thereafter as practicable.

          The Company hereby affirms that it is aware of its obligations under the Securities Act. In connection with the foregoing request, the Company further acknowledges that:

• should the Commission or the staff (the “Staff”) of the Commission, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

• the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

• the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

2

          It would be appreciated if, as soon as the Registration Statement is declared effective, you would so inform the Company’s counsel, Erik R. Tavzel, at (212) 474-1796, and then send written confirmation to the addressees listed on the cover of the Registration Statement.

Sincerely,   Biovail Corporation,
By:	/s/	Jennifer Tindale
	Name:	Jennifer Tindale
	Title:	Vice President, Associate General Counsel and Corporate Secretary