Aradigm Corporation
3929 Point Eden Way
Hayward, CA 94545
November 28, 2018
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Aradigm Corporation |
Request to Withdraw Registration Statement on FormS-1, as amended
FileNo. 333-221352
Ladies and Gentlemen:
Pursuant to Rule 477 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), Aradigm Corporation, a California corporation (the “Company”), hereby respectfully requests that the Securities and Exchange Commission (the “Commission”) consent to the withdrawal, effective as of the date hereof or at the earliest practicable date hereafter, of the Company’s Registration Statementon Form S-1 (FileNo. 333-221352), together with all amendments and exhibits thereto (collectively, the “Registration Statement”). The Registration Statement was originally filed with the Commission on November 3, 2017.
The grounds upon which the Company is making this application for withdrawal are that the Company does not intend to proceed with the previously proposed public offering of its shares of common stock under the Registration Statement at this time. The Registration Statement has not been declared effective by the Commission and the Company confirms that no securities have been sold or will be sold under the Registration Statement or in connection with the previously proposed offering thereunder. Therefore, withdrawal of the Registration Statement is consistent with the public interest and the protection of investors, as contemplated by paragraph (a) of Rule 477 under the Securities Act.
The Company acknowledges that no refund will be made for fees paid to the Commission in connection with filing of the Registration Statement; however, the Company requests, in accordance with Rule 457(p) under the Securities Act, that all fees paid to the Commission in connection with the filing of the Registration Statement be credited to the Company’s account to be offset against the filing fee for any future registration statement or registration statements that the Company may file with the Commission.
If you have any questions or comments or require further information regarding this application of withdrawal of the Registration Statement, please do not hesitate to call ore-mail Jon Layman at (650)463-4024 orjon.layman@hoganlovells.com.
[Signature page follows]
| Very truly yours, | ||
| Aradigm Corporation | ||
| By: | /s/ John M. Siebert | |
| John M. Siebert | ||
Executive Chairman, Interim Principal Executive Officer, and Acting Principal Financial Officer | ||
