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SEC Acceleration Request / Cumberland

CUMBERLAND PHARMACEUTICALS INC.

2525 West End Avenue

Suite 950

Nashville, TN 37203

August 5, 2009

Via Facsimile (202-772-9217) and EDGAR

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: Jeffrey Riedler, Esq.

    Re:

    Cumberland Pharmaceuticals Inc.

    Registration Statement on Form S-1

    Commission File No. 333-142535 (the “Registration Statement”)

Ladies and Gentlemen:

     Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Cumberland
Pharmaceuticals Inc. hereby requests, with respect to the above-captioned registration statement
(“Registration Statement”), that the effective date for the Registration Statement be accelerated
so that it be declared effective at 3:00 p.m. EDT on Monday, August 10, 2009, or as soon thereafter
as possible.

     The Registrant acknowledges that (i) should the Commission or the staff of the Commission,
acting pursuant to delegated authority, declare the filing effective, such declaration does not
foreclose the Commission from taking any action with respect to the filing; (ii) the action of the
Commission or the staff of the Commission, acting pursuant to delegated authority, in declaring the
filing effective, does not relieve the Registrant from its full responsibility for the adequacy and
accuracy of the disclosure in the filing; and (iii) the Registrant may not assert 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.

    Sincerely,

CUMBERLAND PHARMACEUTICALS INC.

    By:
         /s/ A.J. Kazimi

         A.J. Kazimi

         Chief Executive Officer

    cc:

    Rose Zukin, Esq., United States Securities and Exchange Commission

Martin Brown, Esq., Adams and Reese LLP

Donald J. Murray, Esq., Dewey & LeBoeuf LLP

August 5, 2009

BY FACSIMILE AND EDGAR

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Cumberland Pharmaceuticals Inc.

Registration Statement on Form S-1

File No. 333-142535

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned, as the
representatives of the prospective underwriters of the proposed sale of Common Stock of Cumberland
Pharmaceuticals Inc. (the “Company”), hereby join in the request of the Company that the
effectiveness of the Registration Statement on Form S-1 (File No. 333-142535) relating to such
shares be accelerated so that the Registration Statement will become effective by 3:00 P.M. Eastern
Time on Monday, August 10, 2009, or as soon thereafter as practicable.

Pursuant to Rule 460 under the Securities Act of 1933, as amended, and in connection with the
foregoing, please note that we have effected to date approximately the following distribution of
the Preliminary Prospectus dated July 29, 2009:

    5,101

    to

    2,680

    institutions/individuals

    9,600

    to

    4

    prospective underwriters

    0

    to

    0

    others.

* * *

    Very truly yours,

    UBS Securities LLC
 Jefferies
and Company, Inc.
 Wells
Fargo Securities, LLC
 Morgan
Joseph & Co. Inc.

    By: UBS Securities LLC

    By: /s/ Daniel H. Klausner

    Name: Daniel H. Klausner
Title:
Executive Director

    By: /s/ Kristen Kusmierz

    Name: Kristen Kusmierz
Title:
Director