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SEC Company Response from APHTON CORP (CIK 0000840319) — Dec 1, 2005

APHTON CORP (CIK 0000840319)
Date: Dec. 1, 2005 · CIK: 0000840319 · Accession: 0001193125-05-235176

AI Filing Summary & Sentiment

File numbers found in text: 333-128244

Date
December 1, 2005
Author
/s/ John McCafferty
Form
CORRESP
Company
APHTON CORP (CIK 0000840319)

Letter

Correspondence Letter

Aphton Corporation

8 Penn Center, Suite 2300

1628 JFK Boulevard

Philadelphia, PA 19103

December 1, 2005

VIA EDGAR

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

Attention: Zafar Hasan

Re: Registration Statement on Form S-1, SEC Registration No. 333-128244 (the “Registration Statement”)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, (the “Securities Act”) Aphton Corporation (the “Company”) requests that the effectiveness of the Registration Statement referenced above be accelerated at 9:00 a.m. on Monday, December 5, 2005, or as soon as possible thereafter.

As requested, the Company acknowledges that the action of the Commission or the staff in declaring this filing effective:

•

does not foreclose the Commission from taking any action with respect to the filing;

•

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 defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely,
Aphton Corporation

Show Raw Text
CORRESP
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Correspondence Letter

 Aphton Corporation

 8 Penn Center, Suite 2300

 1628 JFK Boulevard

 Philadelphia, PA 19103

 December 1, 2005

 VIA EDGAR

 Securities and Exchange Commission

 450 Fifth Street, N.W.

 Washington, D.C. 20549

 Attention: Zafar Hasan

Re:
Registration Statement on Form S-1, SEC Registration No. 333-128244 (the “Registration Statement”)

 Ladies and Gentlemen:

 Pursuant to Rule 461 under the Securities Act of 1933, as amended, (the “Securities
Act”) Aphton Corporation (the “Company”) requests that the effectiveness of the Registration Statement referenced above be accelerated at 9:00 a.m. on Monday, December 5, 2005, or as soon as possible thereafter.

 As requested, the Company acknowledges that the action of the Commission or the staff in
declaring this filing effective:

•

does not foreclose the Commission from taking any action with respect to the filing;

•

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 defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Sincerely,

 Aphton Corporation

 /s/ John McCafferty

 John McCafferty

 Vice President and Corporate Counsel