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Via Facsimile and U.S. Mail Mail Stop 4720                                                                                                   November 13, 2009   Mr. Craig A. Tooman EVP, Finance & 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, 2008 DEF 14A filed April 13, 2009
 File No. 0-12957

Dear Mr. Tooman:
We have limited our review of your filings to those issues we have addressed in
our comments. In our comments, we ask you to  provide us with information to better
understand your disclosure.  Where a commen t requests you to revise disclosure, the
information you provide should show us what the revised disclosure will look like and
identify the annual or interim filing, as appli cable, in which you intend to first include it.
If you do not believe that revised disclosure  is necessary, explai n the reason in your
response.  After reviewing the informati on 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 any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for the fiscal year ended December 31, 2008

(2) Summary of Significant Accounting Policies

Accruals for Medicaid Rebates, Returns, Chargebacks and Distribution Service Fees,
page F-9
 1. Your policy states that “product retu rns are accrued based on historical
experience, projected future prescriptions of the products using historical data and
the amount and expiry of inventory estimat ed to be in the distribution channel,

Mr. Craig A. Tooman
Enzon Pharmaceuticals, Inc. November 13, 2009 Page 2
 based on information obtained from the company’s major customers”. Please
revise your disclo sure to state:
• your return policy, including the peri od in which you allow products to be
returned, whether you allow them to be  returned close to or after their
expiration date and how you account for returns:
• whether you refund the sales price either  in cash or credit, or whether you
exchange the product from your inventory;
• what happens to returned product; and
• for those returns that you exchange the product from your inventory,  how
you account for your estimate of these re turns at the time of sale of the
product and how you account for returns at the date they are actually
returned to you.  Provide us an  analysis supporting your accounting
treatment with referen ce to the author itative literature  you rely upon to
support your accounting.  It also may be helpful to provide us an example showing the journal entries made.
 (15) Stock Options. F-24

(16) Restricted Stock and Rest ricted Stock Units, page F-25
(17) Employee Stock Purchase Plan, page F-26

2. Please revise your disclosure to quantif y and identify the income statement line
items your stock compensation expense is classified as “recorded in the same
expense categories in the consolidated st atement of operations as the underlying
employee compensation” is vague and “p redominantly in selling, general and
administrative expenses” is not clear.
 Signatures, page 68

3. The Form 10-K should also be signed by the company’s controller or principal
accounting officer.  Any person who occupi es more than one of the specified
positions required to sign the Form 10-K should indicate each capacity in which
he signs the report.  See General Instruction D to Fo rm 10-K.  Unless the person
who serves as your controller or prin cipal accounting officer, as reflected in
previous reports filed with the Commissi on, has already signed the Form 10-K, an
amendment should be filed reflecting the si gnature of your controller or principal
accounting officer.  Please advise.

Definitive Proxy Statement

Annual Performance-Based Incentive Compensation, page 14
4. We note that bonus payments are ba sed upon the Compensation Committee’s
consideration of corporate goals and pe rformance objectives and the qualitative
performance of each officer during the previous year.  The Compensation

Mr. Craig A. Tooman
Enzon Pharmaceuticals, Inc. November 13, 2009 Page 3
 Discussion and Analysis does not disclose  the individual performance objectives
the Compensation Committee considered to  determine your executive officers’
bonus payments.  Please provide us w ith draft disclosure for your 2010 proxy
statement which provides the following:
• A more detailed specific description and quantification of each of the
individual and corporate goals and performance objectives; and
• A discussion of how the level of achievement will affect the actual
bonuses to be paid.

To the extent that these criteria ar e quantified, the disc ussion in your proxy
statement should also be quantifie d. Confirm that you will discuss the
achievement of the objectives.

* * *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that  keys your response to our
comments and provide the requested information.  Detailed letters gr eatly facilitate our
review.  Please furnish the letter to us via 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 any action with respect to the filing; and
‚ the company may not assert staff comments 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 advise d that the Division of Enfo rcement 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.

Mr. Craig A. Tooman
Enzon Pharmaceuticals, Inc. November 13, 2009 Page 4
 Please contact Sasha Parikh, Staff Acc ountant, at (202) 551-3627 or Mark
Brunhofer, Senior Staff Account ant, at (202) 551-3638 if you have questions regarding
the processing of your response as well as any questions regarding comments one and
two.  Please contact John Krug, Staff Attorn ey, at (202) 551-3862 if you have questions
regarding comments three and four .  In this regard, do not hes itate to contact me at (202)
551-3679.

Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant