ARADIGM CORPORATION
3929 Point Eden Way
Hayward, Califronia 94545
July 7, 2016
Via EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street N.E.
Washington, D.C. 20549
| Re: | Aradigm Corporation Registration Statement on Form S-1 Filed May 12, 2016 (File No. 333-211329), as amended |
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), Aradigm Corporation (the “Company”) requests that the effective date of the Company’s Registration Statement on Form S-1 (File No. 333-211329) , as amended (the “Registration Statement”), be accelerated so that the Company’s Registration Statement will become effective at 4:00 PM, eastern time, on July 8, 2016, or as soon as thereafter as is practicable.
In connection with this request, we acknowledge to the Securities and Exchange Commission (the “SEC”) that:
| • | should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| • | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please feel free to direct any questions or comments concerning this request to Jon Layman, Esq. of Hogan Lovells US LLP at 415-374-2373.
| ARADIGM CORPORATION | ||
| By: | /s/ Nancy Pecota | |
| Nancy Pecota | ||
| Chief Financial Officer | ||
