Securities Exchange Act of 1934
Rule 12h-3

March 10, 2006

Response of the Office of Chief Counsel
Division of Corporation Finance

Based on the facts presented, the Division will not object if IVAX Corporation does not file its annual report on Form 10-K for the fiscal year ended December 31, 2005. In reaching this position, we note that IVAX already has filed post-effective amendments removing from registration unsold securities under all effective registration statements on Form S-3 and Form S-8. We assume that, consistent with the representations made in your letter, IVAX will file certifications on Form 15 making appropriate claims pursuant to Rule 12h-3 under the Securities Exchange Act of 1934 prior to the due date of its Form 10-K for the fiscal year ended December 31, 2005.

This position is based on the representations made to the Division in your letter. Any different facts or conditions might require the Division to reach a different conclusion. Further, this response expresses the Division's position on enforcement action only and does not express any legal conclusion on the question presented.

Incoming Letter:

The Incoming Letter is in Acrobat format.

http://www.sec.gov/divisions/corpfin/cf-noaction/ivax031006.htm