Megan N. Gates | 617 348 4443 | mngates@mintz.com One Financial Center Boston, MA 02111 617-542-6000 617-542-2241 fax www.mintz.com

August 29, 2013

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Jeffrey P. Riedler, Assistant Director

Re: OXiGENE, Inc.

Registration Statement on Form S-1

Filed August 8, 2013

File No. 333-190464

Dear Mr. Riedler:

We are submitting this letter on behalf of OXiGENE, Inc. (the “Company”) in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received by letter dated August 14, 2013 (the “Comment Letter”) from the Staff to Dr. Peter J. Langecker, the Company’s Chief Executive Officer, relating to the above-referenced registration statement on Form S-1 of the Company, filed with the Commission on August 8, 2013. In conjunction with this letter, the Company is filing Amendment No. 1 to the registration statement (“Amendment No. 1” and, as amended, the “Registration Statement”).

For convenient reference, we have set forth below in italics the Staff’s comment as set forth in the Comment Letter and have keyed the Company’s responses to the numbering of the comments and the headings used in the Comment Letter. The response is based on information provided to Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C. by representatives of the Company. Where appropriate, the Company has responded to the Staff’s comments by making changes to the disclosure in the Registration Statement as set forth in Amendment No. 1.

Registration Statement

1. Although Rule 430A of the Securities Act of 1933 permits registrants to omit certain pricing-related information from a registration statement that is declared effective, your filing must include the amount of securities to be offered in a pre-effective amendment.

Accordingly, please revise your disclosure to specify:

• The number of units to be sold;

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

BOSTON | LONDON | LOS ANGELES | NEW YORK | SAN DIEGO | SAN FRANCISCO | STAMFORD | WASHINGTON

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

August 29, 2013

Page 2

• The number of shares of common stock per unit;

• The number of warrants per unit; and

• The number of shares of common stock issuable upon exercise of the warrants.

Response: The Company acknowledges the Staff’s comment and notes that such information has been included in Amendment No. 1 to the Registration Statement. Please note that the Company now intends to sell only common stock in the offering to the public, so references to the units and to warrants have been removed, other than warrants to be issued to the placement agent.

*        *        *         *        *

The Company acknowledges that (i) the Company is responsible for the adequacy and accuracy of the disclosure in the filing, (ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing and (iii) the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

When appropriate, the Company will provide a written request for acceleration of the effective date of the Registration Statement and will include the requested “Tandy” language therein. The Company is aware of its obligations under Rules 460 and 461 regarding requesting acceleration of the effectiveness of the Registration Statement.

We hope that the above response and the related revisions to the Registration Statement will be acceptable to the Staff. Please do not hesitate to call the undersigned at (617) 542-6000 with any comments or questions regarding the Registration Statement and this letter.

Sincerely,

/s/ Megan N. Gates

Megan N. Gates

cc:	Securities and Exchange Commission
	Mr. Matthew Jones Mr. Bryan Pitko
	OXiGENE, Inc.
	Peter J. Langecker, M.D., Ph.D. Ms. Barbara Riching
	Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
	Ms. Melanie Ruthrauff