SEC Company Response from AXM PHARMA INC (CIK 0001113643) — Jun 14, 2005
AXM PHARMA INC (CIK 0001113643)
Date: June 14, 2005 · CIK: 0001113643 · Accession: 0001121781-05-000156
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File numbers found in text: 333-124945
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CORRESP 1 filename1.htm AXM Pharma, Inc. LAW OFFICES OF LOUIS E. TAUBMAN, P.C. 225 Broadway, Suite 1200 New York, New York 10007 (212) 732-7184 Fax: (212) 202-6380 E-mail: Louistlaw@aol.com June 14, 2005 U.S. Securities and Exchange Commission Division of Corporate Finance 450 Fifth Street, N.W. Washington, D.C. 20549-0303 Re: AXM Pharma, Inc. Registration Statement on Form S-3 File No. 333-124945 Dear Sir or Madam: We are counsel to AXM Pharma, Inc. (the “Company”). On behalf of our client, we request acceleration of the effective date of the Company’s Pre-Effective Amendment No. 2 to its Registration Statement on Form S-3 as filed with the Commission on June 10, 2005 to become effective at 4:00 p.m. eastern standard time on Tuesday, June 14, 2005, or as soon thereafter as practicable. We, on behalf of the Company hereby acknowledge that · Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; · The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and, · The company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please feel free to contact the undersigned if you have any questions regarding the filing or this letter. Very truly yours, /s/ Louis E. Taubman Louis E. Taubman