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13 June 2005

VIA EDGAR and FEDERAL
EXPRESS

Mr. Brian Cascio
Accounting
Branch Chief
United States Securities
and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20459-0306

Re:
Antares
Pharma, Inc.
Form
10-K for the Year Ended December 31, 2004
Commission File No. 1-32302
   Filed
March 17, 2005

Dear Mr. Cascio:

On behalf of Antares Pharma, Inc.
(the “Company”), following are the Company’s responses to the Staff’s
comment on the above-captioned filing conveyed in the Staff’s comment letter dated
June 6, 2005 (the “Comment Letter”). The Company’s responses to the Comment
Letter were filed electronically via EDGAR, with three (3) additional courtesy paper
copies being sent to each of you and Ms. Lochhead via Federal Express.

The Company has reproduced the
Staff’s comment in boldface print below, with the Company’s response to such
comment inserted directly below.

Note 10:      Third Party
Supply Agreement

               1.

               We note your response to comment 3.  In future filings, please quantify the
               amount of assembly equipment that is  currently owned by the company and
               being used in your supplier’s assembly operations. Additionally, please
                clarify how you account for and classify the depreciation related to the
               equipment used by your supplier.

In response to this comment, the
Company hereby supplementally informs the Staff as follows: the historical cost of
assembly equipment owned by the Company and used in its suppliers’ assembly
operations is approximately $70,000. All of this equipment was fully depreciated as of
December 31, 2004. In the past, the Company has accounted for and classified the
depreciation related to the equipment used by the Company’s suppliers in the same
manner as it accounts for depreciation on Company-owned tools and molds that are
physically located at supplier molding locations, i.e., depreciation was recorded on a
straight-line basis over the estimated useful life, typically a three to seven

13 June 2005
Mr. Brian Cascio
Page 2

year period and such depreciation was classified as manufacturing
overhead as a cost of inventory produced. The Company hereby advises the Staff that it
will make changes to its future filings based on its response set forth above.

In connection with this response, the
Company acknowledges the following:

o
The
Company is responsible for the adequacy and accuracy of disclosures in the filings;

o

SEC staff comments or changes to disclosure in response to SEC staff comments in the
filings reviewed by SEC staff do not foreclose the SEC from taking any action with respect
to the filing; and

o

The Company may not assert SEC staff comments as a defense in any proceeding initiated by
the SEC or any person under the federal securities laws of the United States.

If you have any questions regarding
the above response, please feel free to contact the undersigned at (610) 458-6200.

Sincerely,

/S/ LAWRENCE M. CHRISTIAN
Lawrence
M. Christian
Chief Financial Officer
and Vice President, Finance

cc:
Ms.
Kristin Lochhead
Staff Accountant
United
States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington
DC 20549

Jeffrey
Cotter, Esq.
Leonard Street
and Deinard Professional Association
150 South Fifth Street, #2300
Minneapolis,
MN 55402

Mr.
Thomas Garton
KPMG
LLP
90
South Seventh Street
Minneapolis, MN 55402

Mr.

                     Jack E. Stover
CEO, Antares Pharma, Inc.