Via Facsimile and U.S. Mail
Mail Stop 03-09

	December 9, 2004

Thomas N. Konatich
Acting Chief Financial Officer
SIGA Technologies, Inc.
420 Lexington Avenue
Suite 601
New York, New York 10170

Re:	SIGA Technologies, Inc.
Registration Statement on Form S-3, filed November 24, 2004
File No. 333-120742

Dear Mr. Konatich:

      We have limited our review of the above referenced filing to
only the matters addressed in the following comments.  Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form S-3

Plan of Distribution, starting on page 15
1. Please refer to your statement that "This prospectus covers the
sale of shares of common stock from time to time by the selling
stockholders named in the table above and any of their pledgees,
donees, assignees and successors-in-interest."  Please confirm
your
understanding that selling stockholders must be named before they
can
sell pursuant to the registration statement.  The company may
substitute new names for the names of selling stockholders
identified
in an effective registration statement by means of a Rule 424(b)
prospectus if:
* the change is not material;
* the number of securities or dollar amount registered does not
change; and
* the new owners` securities can be traced to those identified in
the
original registration statement.
2. Please describe to us the transaction whereby ViroPharma
Incorporated and Marc Collett received the securities of the
company
that are the subject of this registration statement.
3. We note your statement that "The selling stockholders also may
loan or pledge the shares to a broker-dealer. The broker-dealer
may
sell the shares so loaned, or upon a default the broker-dealer may
sell the pledged shares pursuant to this prospectus."  Please
provide
us with a detailed explanation of the purpose of the contemplated
"loan or pledge" of shares to broker-dealers.  Please also
describe
the mechanics of the "loan or pledge" and:
* how the transfer will be recorded with respect to each loan or
pledge;
* the terms governing the return of the loaned securities; and
* any consideration to be paid for the loans or pledges.

Please also provide us with any contracts related to this
arrangement.  We may have further comments upon receipt of your
response.
4. Additionally, please explain which parties hold the incidents
of
ownership, such as title, voting rights, and dividend rights, with
respect to the loaned or pledged securities.  We may have further
comments upon receipt of your response.
5. Finally, please tell us if the broker-dealers intend to sell
the
"loaned" securities pursuant to the registration statement.  If
so,
please explain how you will comply with Item 507 of Regulation S-K
and the requirement articulated in comment 1 above that selling
stockholders must be named before they can sell pursuant to the
registration statement.



*	*	*	*	*



      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging 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 staff comments and the declaration
of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.



	Please contact Anne Nguyen, Attorney-Advisor, at (202) 942-
2895
or me at (202) 942-1840 with any questions.

Sincerely,




Jeffrey Riedler
Assistant Director


cc:	Thomas E. Constance
James Grayer
Kramer Levin Naftalis & Frankel LLP
919 Third Avenue
New York, New York 10022
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Thomas N. Konatich
SIGA Technologies, Inc.
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