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