0001387131-14-003990.txt : 20150112 0001387131-14-003990.hdr.sgml : 20150112 20141205170735 ACCESSION NUMBER: 0001387131-14-003990 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20141205 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Adamis Pharmaceuticals Corp CENTRAL INDEX KEY: 0000887247 STANDARD INDUSTRIAL CLASSIFICATION: PHARMACEUTICAL PREPARATIONS [2834] IRS NUMBER: 820429727 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 11455 EL CAMINO REAL STREET 2: SUITE 310 CITY: SAN DIEGO STATE: CA ZIP: 92130 BUSINESS PHONE: (858) 997-2400 MAIL ADDRESS: STREET 1: 11455 EL CAMINO REAL STREET 2: SUITE 310 CITY: SAN DIEGO STATE: CA ZIP: 92130 FORMER COMPANY: FORMER CONFORMED NAME: CELLEGY PHARMACEUTICALS INC DATE OF NAME CHANGE: 19950615 CORRESP 1 filename1.htm

 

 

 

December 5, 2014

 

 

Via EDGAR

 

 

Jeffrey Riedler

Christina De Rosa

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 

 

Re:          Adamis Pharmaceuticals Corporation

Registration Statement on Form S-3

Filed November 21, 2014

File No. 333-200447

 

Dear Mr. Fielder and Ms. De Rosa:

 

Adamis Pharmaceuticals Corporation (“Adamis”) is submitting this letter in response to comments raised in the Staff’s letter to Adamis dated December 1, 2014 (the “SEC Comment Letter”) regarding your review of the above-referenced registration statement on Form S-3 filed by Adamis. In this letter, we have included the comment from the SEC Comment Letter in italics followed by our response. We welcome any questions you may have about our response.

 

Exhibit 5.1

 

1.Please revise the legal opinion filed as Exhibit 5.1 to the registration statement to include an opinion as to Delaware law.

 

Response to Comment 1:

 

In response to the Staff’s comment, we have filed a revised Exhibit 5.1 opinion with Pre-Effective Amendment No. 1 to the Registration Statement on Form S-3 to include an opinion as to Delaware law.

 

You may contact us at (858) 997-2400 if you have any questions regarding the above responses to your comments.

 

Sincerely,

 

 

/s/ Robert O. Hopkins

Robert O. Hopkins, Chief Financial Officer