Pro-Pharmaceuticals, Inc.
7 Wells Avenue
Newton, Massachusetts 02459
Via EDGAR
October 8, 2010
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-4628 U.S.A.
Attention: Tabatha Akins, Staff Accountant
| Re: | Pro-Pharmaceuticals, Inc. |
| Form 8-K |
| Filed September 30, 2010 |
| File No. 001-31791 |
Dear Ms Akins:
In response to your request in your comment letter, dated October 1, 2010, with respect to Pro-Pharmaceuticals, Inc. (the “Company” or “we”) Form 8-K Current Report, which was filed on September 30, 2010, and the Company’s response to your comment letter, dated October 6th, 2010, we acknowledge that:
| • | The Company is responsible for the adequacy and accuracy of the disclosure in the filing; |
| • | Staff comment or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
| • | The “Company” may not assert staff comment as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
If you have any questions, please do not hesitate to contact me at (617) 559-0033 or on my cell at (603) 512-6593.
Sincerely,
/s/ Anthony Squeglia
Chief Financial Officer