[LETTERHEAD OF IMPAX LABORATORIES, INC.]
December 2, 2008
Jeffrey P. Riedler
Assistant Director
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| | Re: | | Impax Laboratories, Inc.
Registration Statement onForm 10-12G, filed October 10, 2008
File No. 0-27354 |
Dear Mr. Riedler:
In connection with responding to the comments raised in the staff’s letter, dated November 7, 2008, Impax Laboratories, Inc. (the “Company”) acknowledges that:
| | • | | the Company is responsible for the adequacy and accuracy of the disclosure in the filings; |
| |
| | • | | staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and |
| |
| | • | | the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
| | | | | |
| | Sincerely,
| |
| | /s/ Arthur A. Koch | |
| | Arthur A. Koch, Jr. | |
| | Senior Vice President, Finance, and
Chief Financial Officer | |
| |
| | | |
| cc: | | Daniel Greenspan |
| | | Suzanne Hayes |
| | | Mary Mast |
| | | Jim Peklenk |
