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SEC Response Letter

 Corcept Therapeutics Incorporated

149 Commonwealth Drive

 Menlo Park, California 94025

 October 24, 2012

 VIA EDGAR

United States

Securities and Exchange Commission

Washington, D.C. 20549

 CORCEPT THERAPEUTICS INCORPORATED HAS

REQUESTED CONFIDENTIAL TREATMENT OF PORTIONS OF

 THIS LETTER IN ACCORDANCE WITH 17 C.F.R. § 200.83

Attention:

Jim B. Rosenberg, Senior Assistant Chief Accountant

Division of Corporation Finance

Re:

Corcept Therapeutics Incorporated

Form 10-K for the Fiscal Year Ended December 31, 2011

Filed March 13, 2012

Form 10-Q for the Quarterly Period Ended June 30, 2012

Filed August 9, 2012

File No. 0-50679

 Dear Mr. Rosenberg,

 Corcept Therapeutics Incorporated (“Corcept” or the “Company”) is transmitting this letter in response to comments received from the staff of the Securities Exchange Commission (the
“Staff”), contained in the Staff’s letter dated September 25, 2012 (“Comment Letter”), with respect to the Company’s Form 10-K for the year ended December 31, 2011 (the “Form 10-K”) and Form 10-Q for
the quarter ended June 30, 2012 (the “Q2 Form 10-Q”). For your convenience, the Staff’s comments are reproduced in bold type below, followed by the Company’s response thereto. The paragraph numbers below correspond to the
numbered paragraphs in the Comment Letter.

 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, page 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 revenues by deducting
from our gross product revenues (a) trade allowances, such as discounts for prompt payment and distributor fees, (b) estimated government rebates and chargebacks, (c) reserves for expected product returns and (d) estimated costs
of patient assistance programs. We initially record estimates for these deductions at the time we recognize the gross revenue. We update our estimates on a recurring basis as new information becomes 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 recognition 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.

 The Company provides the following information regarding charges, payments and reserves
recorded during the quarter ended June 30, 2012:

a)
We accrued approximately $[*****] for the estimated cost of prompt-payment discounts and distributor fees. Our customers earned approximately $[*****] in prompt-payment
discounts and fees during the quarter, leaving a remaining allowance of $[*****]. The remaining allowance was based upon the contracted discount rate for prompt payment applied to all outstanding accounts receivable as of June 30, 2012 given
our expectation that all such amounts would be earned.

b)
We accrued approximately $[*****] for government rebates and chargebacks, none of which had been paid as of the end of the quarter.

For tablets sold to our Specialty Pharmacy (SP) customer, information available to us through the SPARK program (described below) showed
that all of the tablets sold had been dispensed to patients during the quarter or within a few weeks thereafter. Further, this information contained details regarding third-party payor coverage, which we verified with the carriers, allowing us to
estimate the approximate percentage of tablets dispensed to patients that would be paid through government programs.

 As the
sales to the Specialty Distributor (SD) channel are destined for dispending to hospitals to be used in an in-patient

 [*****] –
Confidential information has been omitted and furnished separately to the Securities and Exchange Commission.

setting, these sales are not subject to government rebates and thus no allowances were provided for the quarter ended June 30, 2012 with respect to sales to the SD.

c)
We considered the need for a reserve for possible product returns of tablets sold during the quarter ended June 30, 2012 and determined that no allowance for
product returns from our SP customer was necessary as of June 30, 2012 because all of the tablets sold to the SP customer during the quarter had been sold through to patients within a few weeks after quarter end. With respect to our SD
customer, we determined that no tablets had been sold to hospitals during the quarter and thus deferred the recognition of any revenue from this channel. (Please see our discussion below.)

d)
We accrued approximately $[*****] for the estimated cost of patient assistance programs related to sales during the quarter. We paid approximately $[*****] during the
quarter for such assistance related to tablets dispensed to patients by the SP during the quarter, leaving a balance of $[*****] as of the end of the quarter. The amount paid for such assistance during the quarter was based on requests for
assistance from patients in meeting their insurance deductible and co-pay amounts for the purchase of the medicine dispensed during the quarter. From the data available to us, we were able to determine the percentage of the tablets dispensed for
which assistance was sought and the percentage of assistance actually provided in relation to the sales value of the tablets dispensed. We estimated the full amount of the assistance for the quarter by applying these percentages to the full amount
of sales for the quarter to the SP.

 In consideration of the guidance in ASC
605-15-25-1-(f) and ASC 605-15-25-3 a. through d., the Company advises the Staff that although our product, Korlym™ for Cushing’s syndrome, is new to the market, we can reasonably estimate expected product returns related to current
sales to our SP customer for several reasons: First, we have a carefully controlled patient enrollment program, SPARK (Support Program for Access and Reimbursement for Korlym). SPARK gathers prescription and insurance coverage information directly
from patients and the prescribing physician and manages reimbursement and fulfillment issues, if any arise. Because of SPARK, we have a substantial amount of information about both our patients and their insurers, public and private. Second, we sell
to only two customers, the SP and the SD. As part of our agreement with these customers, in exchange for a data fee, they provide us with information on tablets that they dispense to patients and hospitals. By the end of each reporting period, we
know how much of our product these two customers have sold through to their own customers and thus we are able to reliably estimate how much inventory they hold at period end.

i.
Our SP sells directly to patients, who do not have the right to return medicine once it is shipped to them. Our SD sells to hospital pharmacies. These hospital
pharmacies do have the right, under certain circumstances, to return the product to the SD, and the SD can then return the product back to us.

ii.
Physicians submit prescriptions to SPARK, which verifies the patient’s insurance coverage and transmits the prescription to the SP. The SP then dispenses the
medicine to the patient and collects payment directly from the patient or the patient’s insurance carrier or government payor. The SP then transmits the information regarding the number of tablets dispensed to the patient back to the SPARK
system.

iii.
SPARK maintains data about each patient and prescription. Because we have access to that data, we can determine how many tablets have shipped and to which patients. We
know which insurers or government payors cover those patients. We can also determine the amount of co-pay and other assistance we provided to each patient (if any) through our patient assistance program.

At present, we have relatively few individual sales transactions in the course of a quarter. All of the tablets sold to
the SP were sold in the same bottle configuration and at the same per milligram price. Based on information received from the SP through the SPARK system discussed above, we were able to determine that the SP had dispensed all of these tablets to
patients during the quarter or thereafter through July 17, 2012, based on prescriptions from physicians. Therefore, there was no excess inventory held by the SP as of June 30, 2012.

With respect to the consideration of a reserve for product returns, the Company further advises the Staff that tablets
that have been dispensed to patients may not be returned to the SP or us. Based on the fact that, by the time we filed the Q2 Form 10-Q, all of the tablets that we had sold to the SP during the quarter ended June 30, 2012 had been sold
by the SP to patients, and because these customers have no right to return the medicine, we determined there would be no product returns related to our sales to the SP. We will continue to carefully monitor the levels of inventory held by the SP and
make a determination at least quarterly of the need for and extent of a reserve for product returns from the SP.

We treat sales to our SD customer differently than sales to our SP, because the pharmacies to which the SD sells
may have the right, under certain circumstances, to return product. Furthermore, our review of SPARK data showed that, as of June 30, 2012, the SD had sold [*****] of the product it had purchased from us in the quarter. Accordingly, we
recognized that we did not have a reasonable basis for estimating returns from the SD and therefore deferred the recognition of revenue for the entire amount of our Q2 sales representing approximately $25,000.

The disclosures contained in our Q2 Form 10-Q regarding physician and patient acceptance of Korlym, the medicine’s
return period, and the “potential for slower than anticipated adoption and manufacturing, distribution or other delays” were contained in risk factors designed to advise readers as to issues they should consider before attempting to
estimate our future sales or investing in our stock. These are also factors we weighed when we determined to treat all of our sales to the SD as deferred revenue. For a discussion of our treatment of these risks with respect to our inventory
disclosures, please see below.

 [*****] –
Confidential information has been omitted and furnished separately to the Securities and Exchange Commission.

 Page 2
of 6

 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.

 The approval of Korlym by the United States Food and Drug Administration
(FDA) was considered highly uncertain for a number of reasons. First, this was the first product that would be approved for Cushing’s syndrome. Second, this was the first product for which the Company was seeking approval in any market and this
was the first New Drug Application (NDA) that we had submitted. Third, the tablet manufacturer for Korlym’s tablets [*****]. In addition, the FDA review process is lengthy (taking approximately 10 months from the submission of the NDA for
Korlym to the date of approval) and, during the course of the regulatory review process, there was no way for us to predict the outcome. Questions may come from a number of divisions within the FDA at any time during the process; while the timing of
submission of responses to questions is within our control, there is no direct feedback from the FDA on the acceptability of the responses. A company does not receive any indication from the FDA of the likelihood of outcome until the actual receipt
(or denial) of approval. Also, there was no Advisory Committee meeting related to Korlym that might have given some indication of whether the product would be approved. Thus, given this degree of uncertainty, we could not assert that there was
probable future benefit for the purchases of materials and costs incurred prior to the FDA approval of Korlym in February 2012 in order for them to qualify as an asset.

As part of the drug approval process, the FDA requires pharmaceutical companies to manufacture a certain number of drug
“validation batches.” Each company must submit an analysis of these validation batches for the FDA’s review and the development of a product cannot be completed until after these costs are incurred and the FDA completes its review of
this analysis. If the FDA approves the drug, medicine from the validation batches can be sold to customers. In addition, in order to be prepared for a possible positive outcome and because of the lengthy manufacturing process, we chose to purchase
additional quantities of the Active Pharmaceutical Ingredient (API) in Korlym prior to product approval.

Because Korlym’s approval by the FDA was highly uncertain at the time we incurred the costs related to the Korlym
validation batches and the purchase and micronization of the API, we determined that it was not appropriate to capitalize the cost of any material purchased or manufactured for us prior to the actual receipt of FDA approval of the marketing of the
product. We determined that such costs were covered under the guidance in the Research and Development Topic in accordance with ASC 730-10-15-3 as activities surrounding the acquisition, manufacture and packaging of a product are an integral part of
the development of a product that, at this time, could not and might never have been able to be sold.

 The
following table summarizes amounts that we classified as research and development expense prior to FDA approval that relate to the validation batches and API purchases that became available for commercial use upon FDA approval:

 Period

 Amount, in thousands

 Years Ended December 31,

         2009

$ [*****]

         2010

   [*****]

         2011

   [*****]

 Six-month Periods Ended June 30,

         2011

   [*****]

         2012

   [*****]

 We determined that these activities did not constitute transactions or activities under
ASC 730-10-15-4 for the following reasons. To facilitate our response, the following references are to the subparagraphs of the guidance.

 Guidance Subparagraph

 Company Response

 a)      Accounting for the costs of research and development activities conducted for others under
a contractual arrangement.

Our activities related to research and development efforts for our own benefit and did not relate to activities conducted for
others.

 [*****] –
Confidential information has been omitted and furnished separately to the Securities and Exchange Commission.

 Page 3
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 Guidance Subparagraph

 Company Response

 b)      Activities that are unique to entities in the extractive industries.

The activities did not re