|
| DANIEL B. ENG |
| DIRECT DIAL: 916-930-2551 |
| E-MAIL: daniel.eng@bullivant.com |
June 23, 2010
|
| Mr. Perry Hindin |
| U.S. Securities and Exchange Commission |
| Division of Corporation Finance |
| Mail Stop 3628 |
| One Station Place |
| 100 F Street, NE |
| Washington, DC 20549-3628 |
| |
| Re: | Dragon Pharmaceutical Inc. |
| | Preliminary Proxy Statement on Schedule 14A |
| | Filed on June 23, 2010 |
| | File No. 0-27937 |
| |
| | Schedule 13E-3 |
| | Filed on June 23, 2010 |
| | File No. 005-79304 |
Dear Mr. Hindin:
In connection with Dragon Pharmaceutical Inc.’s (the “Company’s”) filing amendments to its preliminary proxy statement on Schedule 14A and Schedule 13E-3 on June 23, 2010, we are providing this letter in response to the Staff’s comments.
Schedule 13E-3
The cautionary language preceding Exhibits 16(a)(1) and 16(a)(2) has been deleted.
Revised Preliminary Proxy Statement on Schedule 14A
Canaccord Financial’s discussion on page 26 has been revised to discuss in further detail the differences between the March 3 and March 24, 2010 presentations and reasons for such differences.
| | |
 | 1415 L Street, Suite 1000, Sacramento, CA 95814 • 916.930.2500 Fax 916.930.2501 | |
| www.bullivant.com | Seattle Vancouver Portland Sacramento San Francisco Las Vegas | |
| |
|
| Mr. Perry Hindin |
| U.S. Securities and Exchange Commission |
| Division of Corporate Finance |
| June 23, 2010 |
| Page 2 |
If you have any questions or for further discussions relating to this matter please feel free to contact me at (916) 930-2551.
| |
| Very truly yours, |
| |
| /s/ Daniel B. Eng |
| |
| Daniel B. Eng |
DBE:dh
| |
| cc: | Mr. Scott Y. Guan, Jade & Fountain (via email) |
| | Mr. Peter Mak, Chairperson of the Special Committee of the Board of Directors (via email) |
| | Mr. Leo Raffin, Lang Michener LLP (via email) |
| | Mr. Kenneth Sam, Dorsey & Whitney (via email) |
| | Ms. Maggie Deng (via email) |
| | |
| www.bullivant.com | Seattle Vancouver Portland Sacramento San Francisco Las Vegas | |
| |
