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SEC Company Response from CUMBERLAND PHARMACEUTICALS INC (CPIX) (CIK 0001087294) (CPIX) — Jul 6, 2007

CUMBERLAND PHARMACEUTICALS INC (CPIX) (CIK 0001087294)
Date: July 6, 2007 · CIK: 0001087294 · Accession: 0000950144-07-006412

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File numbers found in text: 333-142535

Referenced dates: June 8, 2007

Date
June 28, 2007
Author
ADAMS AND REESE LLP
Form
CORRESP
Company
CUMBERLAND PHARMACEUTICALS INC (CPIX) (CIK 0001087294)

Letter

June 28, 2007

VIA FED EX

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention:

Mr. Jeffrey P. Riedler

Assistant Director

Re:

Cumberland Pharmaceuticals Inc. (the “Company”)

Form S-1 Registration Statement

File No. 333-142535

Ladies and Gentlemen:

We are responding supplementally to comments received in a letter dated June 8, 2007 from Mr. Jeffrey P. Riedler to Mr. A.J. Kazimi with respect to the Form S-1 Registration Statement of Cumberland Pharmaceuticals Inc. filed on May 1, 2007.

Please note that the Company has determined that it no longer intends to include graphic materials in the prospectus. Accordingly, we will not be providing the Commission with a copy of any graphic materials in connection with this Registration Statement.

If you have any additional questions, please call the undersigned at (615) 259-1479.

Sincerely yours,
ADAMS AND REESE LLP

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CORRESP
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CORRESP

June 28, 2007

VIA FED EX

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Attention:

    Mr. Jeffrey P. Riedler

    Assistant Director

    Re:

    Cumberland Pharmaceuticals Inc. (the “Company”)

    Form S-1 Registration Statement

    File No. 333-142535

Ladies and Gentlemen:

     We are responding supplementally to comments received in a letter dated June 8, 2007 from Mr.
Jeffrey P. Riedler to Mr. A.J. Kazimi with respect to the Form S-1 Registration Statement of
Cumberland Pharmaceuticals Inc. filed on May 1, 2007.

     Please note that the Company has determined that it no longer intends to include graphic
materials in the prospectus. Accordingly, we will not be providing the Commission with a copy of
any graphic materials in connection with this Registration Statement.

     If you have any additional questions, please call the undersigned at (615) 259-1479.

Sincerely yours,

ADAMS AND REESE LLP

/s/
Martin S. Brown, Jr.

    cc:

    Greg Belliston, United States Securities and Exchange Commission

    A.J. Kazimi, Cumberland Pharmaceuticals Inc.

    Donald J. Murray, Esq., Dewey Ballantine LLP, Counsel to the underwriters