Via Facsimile and U.S. Mail Mail Stop 6010 January 17, 2006 Mr. David Platt, Ph.D. Chief Executive Officer Pro-Pharmaceuticals, Inc. 189 Wells Avenue Newton, Massachusetts 02459 Re: Pro-Pharmaceuticals, Inc. Form 10-K for the Fiscal Year Ended December 31, 2004 Filed April 7, 2005 File No. 000-31791 Dear Mr. Platt: We have completed our review of your Form 10-K and have no further comments at this time. Sincerely, Jim Atkinson Accounting Branch Chief ?? ?? ?? ??