Access
Pharmaceuticals, Inc.
2700
Stemmons Freeway, Suite 176
Dallas,
Texas 75307
(214)
905-5100
December
21, 2007
VIA
EDGAR
Securities
and Exchange Commission
Division
of Corporation Finance
United
States Securities and Exchange Commission
100
F
Street, N.E.
Washington,
DC 20549
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|
Re:
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Access
Pharmaceuticals, Inc.
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|
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Registration
Statement on Form SB-2
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Dear
Ladies and Gentleman:
The
undersigned, as Chief Financial
Officer of Access Pharmaceuticals, Inc. (the
“Company”), hereby informs the Securities and Exchange Commission
(the
“Commission”) that the Company has determined not to proceed with the
resale registration of shares of its common stock as contemplated in its
Registration Statement on Form SB-2, as amended (File No. 333-147976) (the
“RegistrationStatement”). Therefore, the Company hereby
requests, pursuant to Rule 477 promulgated under the Securities Act of 1933,
as
amended, that the Commission consent to the withdrawal of the Registration
Statement, together with all amendments and exhibits thereto. No
securities were sold in connection with this offering. This letter
will serve to confirm on behalf of the Company that no shares of common stock
of
the Company have been or will be issued or sold pursuant to the Registration
Statement.
If
you have any questions or comments
or require further information or documentation regarding the foregoing, please
do not hesitate to call the undersigned at (214) 905-5100 or John J. Concannon,
Esq. of Bingham McCutchen LLP, counsel to the Company, at (617)
951-8874.
Very
truly yours,
/s/
Stephen B.
Thompson
Stephen
B. Thompson
Vice
President
Chief
Financial Officer