SecProbe.io

September 25, 201 2

Via E -mail
Joseph K. Belanoff
Chief Executive Officer
Corcept Therapeutics, Inc.
149 Commonwealth Drive
Menlo Park, CA 94025

Re:  Corcept Therapeutics, Inc.
Form 10-K for the Fiscal Year Ended December 31, 20 11
Filed March 13, 201 2
Form 10 -Q for the Quarterly Period Ended June 30, 2012
Filed August 9, 2012
File No. 0 -50679

Dear Mr. Belanoff :

We have reviewed your filing s and have the following comments.   In our comments, we
ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within 10 business days by providing the requested
information or by advising us when you will provide the requested response.   If you do not
believe  a comment appl ies to your facts and circumstances, please tell us why in your response.
Please furnish us a letter on EDGAR under the form type label CORRESP that keys your
response s to our comment s.

After reviewing the informatio n provided, we may have additional comments and/or
request that you amend your filing s.

Form 10 -Q for the Quarterly Period Ended June 30, 2012
Notes to Condensed Financial Statements

1. Summary of Significant Accounting Policies

Net Product Sales, pa ge 9

1. You state on page 9 that “ We calculate gross product revenues based on  the price that we
charge our customers. We estimate our net product reve nues by deducting from our gross
product revenues (a) trade allowan ces, such as d iscounts for prompt payment and
distributor fees, (b) estimated government  rebates and chargebacks, (c) reserv es for
expected product  returns and (d)  estimated costs of patient as sistance pr ograms. We

Joseph K. Belanoff
Corcept Therapeutics, Inc.
September 25, 2012
Page 2

 initially record estimates for th ese deducti ons at the time we recognize  the gross revenue.
We update our estimates on a recurring b asis as new information becom es available.”
 Please provide us  an analysis of the charges, payments and reserve balance at June
30, 2012 for items (a) through (d) above.
 Please tell us how you were able to comply with the guidance in ASC 605 -15-25-1-(f)
and ASC 605 -15-25-3 a. through d. in determining the amount of your reserve for
returns for this new product allowing for full revenue recognit ion at time of sale.
Address in your response  your concerns , as disclosed,  over physician and patient
acceptability of the product, the lengthy return period and slower than expected
product launch.
 Tell us how you confirmed that there was  not excess inventory held by your single
distributor and specialty pharmacy.

Cost of Sales , page 9

2. You state that “We began capitalizing Korlym production costs as inventory following
approval by the FDA on February 17, 2012.  Prior to receiving the FDA  approval for
Korlym, we expensed all costs related to the manufacturing of the product (including
stability costs and manufacturing overhead) as incurred; we classified these costs as
research and development expense. A portion of the product manufactured  prior to FDA
approval is available for us to use commercially .”  Please tell us  the amount of these costs
classified as research and development expense by year for each of the three years ended
December 31, 2009, 2010 and 2011 and for the six months ended June 30, 2011 and 2012
and how you considered the guidance in ASC 730 -10-15-4 a. through e. in determining
that classifying the manufacturing costs incurred prior to FDA approval as research and
development expenses  complies with GAAP.

3.   Composit ion of Certain Balance Sheet Items
Inventory, page 11

3. It appears your cost of product revenues was only 5.5% of net product revenues for the
quarter ended June 30, 2012.  Please tell us the amount of estimated revenues represented
by inventory on hand at June 30, 2012 for which manufacturing costs were expens ed in
prior periods as research and development expenses (i.e. “zero cost inventories”).  Tell us
when you expect to finish selling these inventories.

4. If the zero cost inventories exceed your estim ated p roduct sales for the next twelve
months, tell us wh y a materi al portion of the $2.4 million i nventory June 30, 2012 should
not be classified as “non -current” assets since your accounting is on a FIFO basis.

5. Tell us what you estimate your gross margin percentage will be after the zero cost
inventories are sold.

6. Please explain why you have only $25,000 in finished goods inventory at June 30, 2012.

Joseph K. Belanoff
Corcept Therapeutics, Inc.
September 25, 2012
Page 3

 7. Please explain why you are carrying the cost of “work -in-progress” inventory on your
financial statements since you contract the manufacture of inventory to a th ird party. Also
explain how the amount is determined.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing s to be certain that the filing s include the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and a dequacy of the disclosures they have made.

 In responding to our comment s, please provide a written statement from the company
acknowledging that:
 the company is responsible for the adequacy and accuracy of the disclosure in the filing s;
 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing s; and
 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any perso n under the federal securities laws of the United States.

Please contact James Peklenk, Staff Accountant, at (202) 551 -3661 or Lisa Vanjoske,
Assistant Chief Accountant, at (202) 551 -3614 if you have any questions  regarding the
comments . In this regard, d o not hesitate to contact me  at (202) 551 -3679.

Sincerely,

/s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant