SecProbe.io

Mail Stop 6010

        August 3, 2007

A.J. Kazimi
Chairman and CEO
Cumberland Pharmaceuticals Inc.
2525 West End Avenue, Suite 950
Nashville, Tennessee 37203

 Re: Cumberland Pharmaceuticals Inc.
  Registration Statement on Form S-1, Amendment 4
  Filed July 23, 2007
  File No. 333-  142535

Dear Mr. Kazimi:

 We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise 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 deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.

 Please understand that the purpose of our re view 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.

FORM S-1

General

1. We received the revised confidential tr eatment application in response to
comment 1.  However, it requests conf idential treatment only through July 18,
2007.  Since that date is now passed, pl ease submit unredacted versions of the
letters on EDGAR.

A.J. Kazimi
Cumberland Pharmaceuticals Inc. August 3, 2007 Page 2
Dilution, page 27

2. You quantify total consideration from  existing shareholders as $12,223,208 which
appears to be inconsistent  with the amounts for pref erred and common stock in
your condensed consolidated balance sheet at March 31, 2007. Please revise the introductory paragraph to the table on  page 28 to clarify how the total
consideration from existing shareholders is calculated.

Exhibit 23.3 – Consent of Morgan Joseph & Co. Inc.

3. Since you have revised the disclosure re lated to your valuation analysis at
December 2006 that Morgan Joseph & Co. Inc. assisted management in its preparing the valuation analysis for boar d review, please file a currently dated
consent from Morgan Joseph & Co. Inc.

* * *
 As appropriate, please amend your regist ration 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 cove r 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 amendmen t and responses to our comments.

 We direct your attention to Rules 460 and 461 regarding requesting acceleration
of a registration statement.  Please allow ad equate time after the filing of any amendment
for further review before submitting a request for acceleration.  Please provide this
request at least two business days in a dvance of the requested effective date.

 You may contact Todd Sherman at (202)  551-3665 or James Rosenberg at (202)
551-3679 if you have questions regarding comm ents on the financial statements and
related matters.  Please c ontact Greg Belliston at (202) 551-3861 or me at (202) 551-3715
with any other questions.

        S i n c e r e l y ,

        J e f f r e y  R i e d l e r
        A s s i s t a n t  D i r e c t o r

cc: Martin S. Brown, Esq.
 Adams and Reese LLP
 424 Church Street, Suite 2800
 Nashville, Tennessee 37219