SecProbe.io

July 30, 2012

Via E -mail
Mr. George W. Hebard III
Interim Principal Executive Officer &
Interim Chief Operating Officer
Enzon Pharmaceuticals, Inc.
20 Kingsbridge Road
Piscataway, NJ 08854

Re:  Enzon Pharmaceuticals, Inc.
 Form 10 -K for the Fiscal Year Ended December  31, 2011
Filed March 12 , 2012
 File No. 000-12957

Dear Mr. Hebard :

We have  reviewed your filing and have the following comments.  In our comments, we
ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within 10 business days by providing the requested
information or by advising us when you will provide the requested respon se.  If you do not
believe a comment applies to your facts and circumstances, please tell us why in your response.
Please furnish us a letter on EDGAR under the form type label CORRESP that keys your
responses to our comments.

After reviewing the informa tion you provide, we may have additional comments and/or
request that you amend your filing .

Santarus Pharma A/S License Agreement, page 12

1. We note your disclosure stating that Santarus may terminate the agreement with respect
to specific LNA compounds  if you do not achieve certain development milestones for
that product. Please discuss the development milestones that must be achieved and the
timeframe for achieving them as to each of the three pipeline products being developed as
a result of this agree ment. Also disclose the year in which the royalty term will expire as
to each of the three pipeline products in each country where patents have been issued or
where patent applications are pending.

Patents and Intellectual Property Rights, page 15

2. We no te your disclosure indicating that the original patent covering the Company's PEG
technology has expired and that current patents cover improved methods of attaching

Mr. George W. Hebard III
Enzon Pharmaceuticals, Inc.
 July 30, 2012
 Page 2

 PEG to therapeutic compounds and PEG -modified compounds that the company has
identified or  created. It is unclear whether any of these current patents are material to
your business. Please provide expiration dates for any of these patents if they are material
or, alternatively, please provide a supplemental analysis detailing why they are not
material to your business. Also, please provide the jurisdiction and expiration dates of
any material patents related to any of the three pipeline products being developed as a
result of the agreement with Santarus.

Management’s Discussion and Analysis of  Financial Condition and Results of Operations
Research and Development Expenses - Pipeline, page 45

3. Please provide us revised proposed disclosure to be presented in future periodic reports
that quantifies the costs incurred during each period presented an d to date for each of
your material R&D programs. Where the sum of the costs incurred by project is
materially different than the total R&D expense shown in the financial statements,
disclose the nature and amount of the items that comprise this difference .

Notes to Consolidated Financial Statements
(6)  Notes Payable, page F -14

4. Please provide us your analysis indicating why you have not bifurcated a derivative
liability for your embedded conversion feature , given that the conversion rate is subject to
change .  Please reference for us the authoritative literature you rely upon to support your
position.

(18) Significant Agreements,
Sigma -Tau Group, page F -27

5. Please  provide us proposed revised disclosure to be included in future periodic reports
that dis closes each of your remaining potential milestone receipts and the other
information required by ASC 605 -25-50-2.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includ es all information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.  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.

 In responding t o our comment s, please provide  a written statem ent 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.

Mr. George W. Hebard III
Enzon Pharmaceuticals, Inc.
 July 30, 2012
 Page 3

You may contact Sasha Parikh , Staff Accountant, at (202) 551 -3627 or Mark Brunhofer ,
Senior Staff Accountant , at (202) 551 -3638 if you have questions regarding the processing of
your response as well as any questions re garding comments on the financial statements and
related matters .  You may contact  Evers on Ladson , Staff Attorney, at ( 202) 551 -3495 or Jeffrey
Riedler, Assistant Director, at (202) 551 -3715  with questions on any of the other comments .  In
this regard, do not hesitate to contact me at (202) 551 -3679 .

Sincerely,

        /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant