ACURA
PHARMACEUTICALS, INC.
November
19, 2007
via
EDGAR
Securities
and Exchange Commission
450
Fifth
Street, N.W.
Washington,
D.C. 20549
|
Attention:
|
Jeffrey
Riedler, Mail Stop 6010
|
|
|
Assistant
Director, Division of Corporate
Finance
|
|
Re:
|
Acceleration
Request for
|
|
|
Acura
Pharmaceuticals, Inc.
|
|
|
Registration
Statement on Form S-3
|
|
|
File
No. 333-146416 Filed October 1, 2007
and
as Amended on November 14,
2007
|
Ladies
and Gentlemen:
We
respectfully request acceleration of the effective date of our above-captioned
registration statement on Form S-3 under the Securities Act of 1933 to November
20, 2007 at 10 A.M., or as soon after that as practicable. We also acknowledge
and confirm the following:
|
•
|
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 Acura
Pharmaceuticals, Inc. from its full responsibility for the adequacy
and
accuracy of the disclosures in the filing; and
|
|
|
|
|
•
|
Acura
Pharmaceuticals, Inc. may not assert this action as a defense in
any
proceeding by the Commission or any person under the federal securities
laws of the United States.
|
ACURA
PHARMACEUTICALS, INC.
|
By:
|
s/
Peter A. Clemens
|
|
|
Name:
Peter A. Clemens
|
|
|
Senior
Vice President and
|
|
|
Chief
Financial Officer
|