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Via Facsimile and U.S. Mail
Mail Stop 6010

         October 20, 2008

Craig A. Tooman
Executive Vice President, Finance and
Chief Financial Officer
Enzon Pharmaceuticals, Inc.
685 Route 202/206
Bridgewater, NJ 08807

Re:   Enzon Pharmaceuticals, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2007
 Filed February 29, 2008
 File Number:  000-12957

Dear Mr. Tooman:

We have reviewed your filing and have the following comments. We have limited
our review to your financial statements a nd related disclosures and do not intend to
expand our review to other portions of your document. In our comments, we ask you to
provide us with information to better unde rstand your disclosure.  Where a comment
requests you to revise disclosure, the info rmation you provide should show us what the
revised disclosure will look like and identify the annual or quarterly filing, as applicable,
in which you intend to first include it.  If you do not believe that revised disclosure is
necessary, explain the reason in your response.  After reviewing the information
provided, we may raise additional comments and/or request that you amend your filing.

 Please understand that the purpose of our re view 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.

Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
 Critical Accounting Policies and Estimates

Revenues, page 63
 1. Please revise your summary of gross-to -net sales reductions  to include the
provision related to sales ma de in the current period and the provision related to
sales made in prior periods similar to  the format you provided in your response

Craig A. Tooman
Enzon Pharmaceuticals, Inc. October 20, 2008 Page 2
letter dated June 21, 2007.
 Consolidated Financial Statements

 (7) Intangible Assets, page F-22

 2. As product acquisition costs are material, pl ease revise your disc losure to include
the following information about your pr oduct rights by product:  their cost,
accumulated amortization, weighted aver age amortization period, and aggregate
and estimated amortization expense.
 (11) Gain on Sale of R oyalty Interest, page F-25

 3. Please provide us your analysis that allowed you to rec ognize the entire $88.7
million gain on the sale of future royalties  in the current period.  Please include
your consideration of EITF 88-18 in your explanation.

* * * *

 Please provide us the information request ed within 10 busine ss days or tell us
when you will provide us with a response.  Pl ease furnish a cover le tter with your response
that keys your response to our comments.  De tailed cover letters gr eatly facilitate our
review.  Please furnish your letter on EDGAR under the form type label CORRESP.

 We urge all persons who are responsible  for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging that:

• the company is responsible for the adequacy and accuracy of the disclosure in
the filing;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking a ny action with respect to the filing;
and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

Craig A. Tooman
Enzon Pharmaceuticals, Inc. October 20, 2008 Page 3
 In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

You may contact Vanessa Robe rtson, Staff Accountant, at (202) 551-3649 or Joel
Parker, Accounting Branch Chief, at (202) 551-3651 if you have any questions regarding
the comments.  In this regard, do not he sitate to contact me, at (202) 551-3679.

        S i n c e r e l y ,

        J i m  B .  R o s e n b e r g
Senior Assistant Chief
Accountant