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SEC Comment Letter for ANTARES PHARMA INC (CIK 0001016169) — Aug 12, 2005

ANTARES PHARMA INC (CIK 0001016169)
Date: Aug. 12, 2005 · CIK: 0001016169 · Accession: 0000000000-05-041697

AI Filing Summary & Sentiment

File numbers found in text: 333-109114

Date
August 9, 2005
Author
Russell Mancuso
Form
UPLOAD
Company
ANTARES PHARMA INC (CIK 0001016169)

Letter

Re: Antares Pharma, Inc. Post Effective Amendment on Form S-3 Filed July 22, 2005 File No. 333-109114 Dear Mr. Christian We have limited our review of your filing to those issues we have addressed in our comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.

August 9, 2005

Mail Stop 6010

Lawrence M. Christian Chief Financial Officer Antares Pharma, Inc. 707 Eagleview Boulevard, Suite 414 Exton, Pennslvania 19341

Please understand that the purpose of our review 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.

Facing Page 1. If your filing is based on Rule 429, please say so and identify the appropriate registration statement in accordance with the requirements of Rule 429(b).

Prospectus 2. We note your reference on page 18 to information in previous prospectuses. Information in prospectuses may not be incorporated by reference to a prior prospectus. Instead, you must file a prospectus that includes all of the information that would be required in a prospectus relating to all offerings that the rule 429 prospectus covers, including a complete, current selling shareholders table.

As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

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 information required under the Securities Act of 1933 and that they have provided all information investors require for an informed investment decision. 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.

Before the amended registration statement is declared effective pursuant to Section 8 of the Securities Act, the company should provide us with a letter, acknowledging 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 staff comments and the declaration of effectiveness 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 advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in connection with our review of your filing or in response to our comments on your filing. You may contact Jay Mumford at (202) 824-5348 or me at (202) 942-3617 with any other questions. Sincerely,

Russell Mancuso Branch Chief

cc: Morris M. Sherman, Esq.

Show Raw Text
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<TEXT>

August 9, 2005

Mail Stop 6010

Lawrence M. Christian
Chief Financial Officer
Antares Pharma, Inc.
707 Eagleview Boulevard, Suite 414
Exton, Pennslvania 19341

Re:	Antares Pharma, Inc.
	Post Effective Amendment on Form S-3
      Filed July 22, 2005
	         File No. 333-109114
Dear Mr. Christian
      We have limited our review of your filing to those issues we
have addressed in our comments.  Where indicated, we think you
should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

      Please understand that the purpose of our review 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.

Facing Page
1. If your filing is based on Rule 429, please say so and identify
the appropriate registration statement in accordance with the
requirements of Rule 429(b).

Prospectus
2. We note your reference on page 18 to information in previous
prospectuses.  Information in prospectuses may not be incorporated
by
reference to a prior prospectus.  Instead, you must file a
prospectus
that includes all of the information that would be required in a
prospectus relating to all offerings that the rule 429 prospectus
covers, including a complete, current selling shareholders table.

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      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 information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment decision.  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.

      Before the amended registration statement is declared
effective
pursuant to Section 8 of the Securities Act, the company should
provide us with a letter, acknowledging 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 staff comments and the declaration
of
effectiveness 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 advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.
      You may contact Jay Mumford at (202) 824-5348 or me at (202)
942-3617 with any other questions.
      Sincerely,

							Russell Mancuso
							Branch Chief

cc:	Morris M. Sherman, Esq.

</TEXT>
</DOCUMENT>