SEC Company Response from HERON THERAPEUTICS, (HRTX) — Sep 5, 2012
HERON THERAPEUTICS, INC. /DE/ (HRTX) (CIK 0000818033)
Date: Sept. 5, 2012 · CIK: 0000818033 · Accession: 0001193125-12-379853
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File numbers found in text: 333-183549
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CORRESP 1 filename1.htm Acceleration Request September 4, 2012 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549-4628 Re: A.P. Pharma, Inc. (the “Company”) Acceleration Request for Registration Statement on Form S-3 File No. 333-183549 Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned, on behalf of the registrant, hereby requests that the effective date of the above-referenced registration statement be accelerated so that it will be declared effective at 4:00 p.m. (Eastern) on Thursday, September 6, 2012, or as soon thereafter as practicable. In making this acceleration request, the Company acknowledges that: • 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 the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and • the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Sincerely, /s/ John B. Whelan John B. Whelan President, Chief Executive Officer and Chief Financial Officer cc: Ryan Murr, Esq. (Ropes & Gray LLP)