Virus-Free, Inc. 1565 Genome Way San Diego, CA 92128 March 29, 2009 Central Document Room Center for Drug Evaluation and Research Food and Drug Administration 5901-B Ammendale Road Beltsville, Maryland 2070501266 Re: AV-5656 Tablets Initial Investigational New Drug Application IND 109,876, Serial Number 0000 Dear Sir or Madam: Virus-Free, Inc. is submitting three copies of an initial Investigational New Drug Application (IND) for AV-5656. The chemical name of the active ingredient is 1,5,7,2tetramethyl, 3-amino, 6-bromo-viruskill. AV-5656 is intended to be studied as a virallysis tablet to treat blood-borne viral infections. At this time, Virus-Free is submitting a protocol to begin a Phase 1, single and multiple dose trial in healthy male and female subjects. This study will be conducted at Florida General Hospital by Betty Sue Lee, M.D. Virus-Free has previously discussed this proposed development plan during a pre-IND meeting with the Division of Antiviral Products on January 5, 2009 and our Phase 1 clinical protocol has been modified as discussed at that meeting. A copy of the minutes from that meeting is included in this submission. Virus-Free commits to conduct this clinical investigation in accordance with all applicable regulatory requirements. Virus-Free will not initiate this clinical study until this IND has become effective and Investigational Review Board (IRB) approval has been received. Virus-Free, Inc. Page two Virus-Free considers the material and data contained in this application to be confidential and not to be publically disclosed. If you have any questions regarding the submitted information, please do not hesitate to contact me by telephone at 858-455-5565 or by email at jstudent@virus-free.com. Sincerely, Joe Student Senior Director, Regulatory Affairs Virus-Free, Inc.