June 8, 2009



VIA EDGAR & FAX

United States Securities and Exchange Commission
100 F Street, NE
Washington DC 20549-7010
Mail Stop 4561

Attn.: Duc Dang, Attorney/Advisor

            Re:   Biocoral Inc.
                  Form 10-K for the year ended December 31, 2007
                  000-23512

Ladies and Gentlemen:

      We are responding to the additional comments of the Securities and
Exchange Commission (the "Commission") to the Annual Report on Form 10-K for the
year ended December 31, 2007 (the "2007 Annual Report") of Biocoral Inc. (the
"Company") by letter dated May 4, 2009 to Mr. Nasser Nassiri, President. In this
regard, we have addressed the various issues raised in your letter to the best
of the Company's ability and have set forth below the Company's responses. The
responses correspond to the numbered items in the Commission's letter. For your
convenience, we have also inserted each of your comments above the corresponding
response.

Financial Condition, Liquidity and Capital Resources, page 16

Fiscal 2008 vs. 2007, page 16

1.    Comment: In response to comment 11 of our letter dated December 2, 2008,
      you stated that you would revise your disclosure to address the impact of
      the current U.S. and global economic crisis on your operations and your
      ability to obtain additional financing. However, in reviewing your current
      10-K, we were not able to locate this disclosure. Please tell us if the
      noted impact continues to apply and revise your future filings
      accordingly.

      Response:

      As it reviewed its financial condition in preparing the Form 10-K
      disclosure, the Company reconsidered the impact of the recession on its
      sources of capital. Although the recent economic slowdown affected sales
      somewhat, it did not appear to have had much of an effect on the Company's
      sources of funding, and its impact overall was insignificant. Management
      believes this is due to its relatively small size and the small scale of
      its operations. The Company intends to continue to monitor the impact, if
      any, of the recession on its financial condition and to update its
      disclosure as needed in future filings.




2.    Comment: We note your response to comment 5 of our letter dated March 6,
      2009 that you do not have a formal written agreement. Therefore, please
      tell us how you have determined that this shareholder will provide the
      additional $121,500 in 2009 and explain why an intention can be classified
      as a commitment on page 16. Further, we note from Note 8 to your financial
      statements that the short-term loans are convertible to promissory notes
      that are due on demand. Please tell us your outstanding debt that is due
      on demand and discuss how a demand on such debt would affect your
      liquidity. Provide similar disclosure in future filings.

      Response:

      The Company revised its disclosure in the 10-Q to replace the word
      "commitment" with "written confirmation." Essentially, an investor on whom
      the Company has relied in the past to provide funding, assured the
      Company's management both orally and by a written confirmation that it
      intended to provide funding.

      As of March 31, 2009, the Company had received advanced funds of $150,000
      that it classified as a short term loan and due on demand. However, at the
      time of funding, the Company informed the investor that the advance would
      be converted into new long term 7% non-convertible notes on terms and
      conditions to be determined. The board of directors is working out the
      terms for the new long term notes. In any event, contrary to the statement
      in the staff's comment, the current disclosure in note 8 does not actually
      indicate, and the Company does not expect, that the new long term notes
      will be due on demand. The Company intends to update its disclosure
      regarding this and the status of its funding in future filings as
      necessary.

      Please do not hesitate to contact me with any further questions or
      comments regarding the foregoing or the Company's disclosure.


                                                              Very truly yours,

                                                              /s/ Mary P. O'Hara

                                                              Mary P. O'Hara

cc:      Stacie D. Gorman






                                 Biocoral, Inc.
                              38 rue Anatole France
                      92594 Levallois Perret Cedex - France



                                                                    June 8, 2009


United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20649

         Re:      Biocoral, Inc.
                  Form 10-K for the year ended December 31, 2007 File No.
                  000-23512

Ladies and Gentlemen:

Biocoral, Inc. (the "Company"), in connection with the response to the
additional comments from the staff of the Securities and Exchange Commission
(the "Commission") by letter dated May 4, 2009 with respect to the
aforementioned Form 10-K, hereby acknowledges the following:

o    the Company is responsible  for the adequacy and accuracy of the disclosure
     in the filing;

o    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

o    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.



                                              Sincerely,

                                              BIOCORAL, INC

                                              By: /s/ Nasser Nassiri
                                              ---------------------------------
                                              Nasser Nassiri, President and
                                              Chief Executive Officer