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SEC Company Response from BIODELIVERY SCIENCES INTERNATIONAL INC (CIK 0001103021) — Jun 10, 2005

BIODELIVERY SCIENCES INTERNATIONAL INC (CIK 0001103021)
Date: June 10, 2005 · CIK: 0001103021 · Accession: 0001193125-05-123791

AI Filing Summary & Sentiment

File numbers found in text: 001-31361

Date
June 10, 2005
Author
Not clearly detected
Form
CORRESP
Company
BIODELIVERY SCIENCES INTERNATIONAL INC (CIK 0001103021)

Letter

VIA EDGAR CORRESPONDENCE Division of Corporate Finance Washington, D.C. 20549 Re: BioDelivery Sciences International, Inc. (the “Company”) Annual Report on Form 10-KSB File No. 001-31361

Dear Ms. Bruckner and Mr. Parker:

Further to our previous conversations, we hereby respectfully submit to you the following on behalf of the Company:

1. Current Report on Form 8-K/A (Amendment No. 2): As requested, this amendment to the Company’s August and November 8-Ks relating to the Arius acquisition is made to change the characterization of Arius to that of a non-development stage company.

2. Annual Report on Form 10-KSB/A (Amendment No. 2): As requested, this amendment is being filed to make certain changes to the footnotes to the Company’s financial statements as you requested. The amendment also attaches, as an exhibit, a letter amendment, dated June 6, 2005, between the Company and Accentia to the license agreement between such parties, which amendment is intended to clarify that the Company has no ongoing material obligations, monetary or otherwise, under such license agreement. The Company hereby confirms that no such obligations exist under the agreement, as amended.

3. Registration Statement on Form SB-2/A (Amendment No. 2): This amendment is being filed to conform changes from the other amendments as well as to bring the document current (March financials, etc.) in anticipation of effectiveness.

Show Raw Text
CORRESP
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SEC Letter

 ELLENOFF GROSSMAN & SCHOLE LLP

 ATTORNEYS AT LAW

 370 LEXINGTON AVENUE

 NEW YORK, NEW YORK 10017

 TELEPHONE: (212) 370-1300

 FACSIMILE:   (212) 370-7889

 www.egsllp.com

 June 10,
2005

 VIA EDGAR CORRESPONDENCE

 AND FEDERAL EXPRESS

 Ms. Amy Bruckner

 Mr. Joel Parker

 Mail Stop 03-09

 United State Securities and Exchange Commission

 Division of Corporate Finance

 450 Fifth Street, N.W.

 Washington, D.C. 20549

Re:
BioDelivery Sciences International, Inc. (the “Company”)

 Annual Report on Form 10-KSB

 File No. 001-31361

 Dear Ms. Bruckner and Mr. Parker:

 Further to our previous conversations, we hereby respectfully submit to you
the following on behalf of the Company:

 1. Current Report
on Form 8-K/A (Amendment No. 2): As requested, this amendment to the Company’s August and November 8-Ks relating to the Arius acquisition is made to change the characterization of Arius to that of a non-development stage company.

 2. Annual Report on Form 10-KSB/A (Amendment No. 2): As
requested, this amendment is being filed to make certain changes to the footnotes to the Company’s financial statements as you requested. The amendment also attaches, as an exhibit, a letter amendment, dated June 6, 2005, between the Company
and Accentia to the license agreement between such parties, which amendment is intended to clarify that the Company has no ongoing material obligations, monetary or otherwise, under such license agreement. The Company hereby confirms that no such
obligations exist under the agreement, as amended.

 3.
Registration Statement on Form SB-2/A (Amendment No. 2): This amendment is being filed to conform changes from the other amendments as well as to bring the document current (March financials, etc.) in anticipation of effectiveness.