February 8, 2007

VIA FACSIMILE (202-772-9217) AND EDGAR

Mr. Jeffrey P. Riedler

Assistant Director

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: Song P. Brandon, Esq.

Re: Targeted Genetics Corporation - Request for Acceleration of Effectiveness of Registration Statement on Form S-3, Commission File No. 333-140187

Dear Mr. Riedler,

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Targeted Genetics Corporation (the “Company”) hereby requests that the effective date of its Registration Statement on Form S-3, Registration No. 333-140187 (the “Registration Statement”) be accelerated so that the Registration Statement may become effective at the later of: (a) 4:00 p.m., Eastern Standard Time, Thursday, February 8, 2007, or as soon as practicable thereafter; and (b) such later time as the Company may request by telephone to the Commission. The Company hereby authorizes Stephen M. Graham or Lewis S. Malakoff of Orrick, Herrington & Sutcliffe LLP, counsel for the Company, to make such a request on its behalf.

We hereby acknowledge that:

·   should the Commission or the staff, 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 this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,

TARGETED GENETICS CORPORATION

/s/ David J. Poston                                                  

David J. Poston

Vice President Finance and

Chief Financial Officer

cc: Orrick, Herrington & Sutcliffe LLP