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CORRESP
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CORRESP

CUMBERLAND PHARMACEUTICALS INC.

2525 West End Avenue

Suite 950

Nashville, TN 37203

August 3, 2007

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 2:00 p.m. EDT on Tuesday, August 7, 2007, 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:

    Greg Belliston, Esq., United States Securities and Exchange Commission

    Martin Brown, Esq., Adams and Reese LLP

    Virginia Boulet, Esq., Adams and Reese LLP

    Donald J. Murray, Esq., Dewey Ballantine LLP