Form: SB-2/A

Optional form for registration of securities to be sold to the public by small business issuers

January 11, 1999

SECURITIES AND EXCHANGE LETTER

Published on January 11, 1999



EXHIBIT 99

Access Pharmaceuticals, Inc.
2600 Stemmons Freeway, Suite 176
Dallas, TX 75207-2107

Janaury 11, 1999

Paul Fischer, Esq.
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549

Re: Registration Statement on Form SB-2; File No. 333-62463

Dear Mr. Fischer:

The undersigned registrant hereby requests that the Securities and
Exchange Commission take appropriate action to cause the effective date
of the above referenced Registration Statement on Form SB-2 to be
accelerated such that the Registration Statement will become effective
at 2:00 p.m. EST on Janaury 11, 1999 or as soon as practicable
thereafter.


Very truly yours

/s/ Kerry P. Gray
-----------------

Kerry P. Gray
President & CEO
Access Pharmaceuticals, Inc.