Aradigm Corporation
39655 Eureka Drive
Newark, CA 94560
October 22, 2019
VIA EDGAR [AND OVERNIGHT DELIVERY]
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, as amended
File No. 333-228636
Ladies and Gentlemen:
Pursuant to Rule 477 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), Aradigm Corporation (the “Company”) hereby requests that the Securities and Exchange Commission (the “Commission”) consent to the withdrawal, effective as of the date hereof or at the earliest possible practicable date hereafter, of its Registration Statement on Form S-1 (File No. 333-228636), together with all amendments and exhibits thereto (collectively, the “Registration Statement”). The Registration Statement was originally filed with the Commission on November 30, 2018.
The Registration Statement was filed in connection with the proposed public offering by the Company of its common stock, which the Company has determined not to pursue at this time. The Registration Statement has not been declared effective and the Company confirms that no securities have been or will be sold pursuant to the Registration Statement.
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 the Company may file with the Commission.
Please send copies of the written order granting withdrawal of the Registration Statement to Bennet Young of Jeffer Mangels Butler & Mitchell LLP, the Company’s counsel, via email atBYoung@jmbm.com.
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 or email Bennet Young at (415) 984-9626 orBYoung@jmbm.com.
[Signature page follows]
Very truly yours,
Aradigm Corporation
/s/ John M. Sibert
John M. Siebert
Acting Principal Executive Officer
[Signature Page to Withdrawal Request Letter]
