| Ryan A. Murr 415.733.6024 rmurr@goodwinprocter.com | Goodwin Procter LLP Counselors at Law Three Embarcadero Center 24th Floor San Francisco, CA 94111 T: 415.733.6000 F: 415.677.9041 |
September 28, 2010
Via EDGAR
Jeffrey Riedler
Assistant Director
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E., Mail Stop 4720
Washington, D.C. 20549
| Re: | Apricus Biosciences, Inc. f/k/a NexMed, Inc. |
| Amendment No. 2 to Registration Statement on Form S-1 |
| File No. 333-169132 |
Dear Mr. Riedler:
As discussed, the above-referenced Registration Statement on Form S-1 of Apricus Biosciences, Inc., has been filed on the date hereof. Please note that Amendment No. 2 has been filed solely for the purpose of adding exhibits to the original filing.
On September 24, 2010, we requested that the above-reference Registration Statement be accelerated to today, Tuesday, September 28, 2010, at 5:30 p.m. (Eastern), or as soon thereafter as practicable. Thank you for your assistance.
Sincerely,
/s/ Ryan A. Murr
Ryan A. Murr
cc: | Bassam B. Damaj, Ph.D., Apricus Biosciences, Inc. (formerly NexMed, Inc.) |