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Published on October 22, 2008
[Access
Letterhead]
October
22, 2008
Securities
& Exchange Commission
Office of
the Chief Counsel
Division
of Corporation Finance
100 F
Street, NE
Washington,
DC 20549
Attn: Mr.
Mark Brunhofer
Dear Mr.
Brunhofer:
In
connection with responding to the comments provided by the Staff of the
Securities and Exchange Commission (“SEC”) in the SEC comment letter dated
September 9, 2008 and the telephonic comments received on October 2, 2008,
Access Pharmaceuticals, Inc. (the “Company”) acknowledges each of the
following:
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·
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the
Company is responsible for the adequacy and accuracy of the disclosure in
the filing;
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·
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staff
comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the
filing; and
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·
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the
Company may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under federal securities laws of
the United States.
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Respectfully,
/s/ Stephen B.
Thompson
Stephen
B. Thompson
Chief
Financial Officer