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SEC Company Response from CUMBERLAND PHARMACEUTICALS INC (CPIX) (CIK 0001087294) (CPIX) — Aug 3, 2007

CUMBERLAND PHARMACEUTICALS INC (CPIX) (CIK 0001087294)
Date: Aug. 3, 2007 · CIK: 0001087294 · Accession: 0000950144-07-007215

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File numbers found in text: 333-142535

Date
August 3, 2007
Author
Director
Form
CORRESP
Company
CUMBERLAND PHARMACEUTICALS INC (CPIX) (CIK 0001087294)

Letter

Re:

August 3, 2007

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

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 2:00 P.M. Eastern Time on Tuesday, August 7, 2007, 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 23, 2007:

3,837 to 2,304

institutions/individuals

1,000 to 1,000

prospective underwriters

5,421 to 3,262

others.

* * *

Very truly yours,
UBS Securities LLC

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CORRESP
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filename1.htm

CORRESP

August 3, 2007

Securities and Exchange Commission

100 F Street, NE

Washington, DC 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 2:00 P.M. Eastern
Time on Tuesday, August 7, 2007, 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 23, 2007:

    3,837 to 2,304

    institutions/individuals

    1,000 to 1,000

    prospective underwriters

    5,421 to 3,262

    others.

* * *

    Very truly yours,

UBS Securities LLC

Jefferies and Company, INC.

Wachovia Capital markets, LLC

Morgan Joseph & Co. INC.

    By:
    UBS Securities LLC

    By:
    /s/ Stephen Helfeld

    Name:
    Stephen Helfeld

    Title:
    Director

    By:
    /s/ Ashish Chabria

    Name:
    Ashish Chabria

    Title:
    Executive Director