SHUMAKER, LOOP & KENDRICK,LLP
101 EAST KENNEDY BOULEVARD, SUITE 2800
Julio C. Esquivel (813) 227-2325 jesquivel@slk-law.com | TAMPA, FLORIDA 33602 (813) 229-7600 FAX (813) 229-1660 | OTHER OFFICE LOCATIONS: CHARLOTTE COLUMBUS TOLEDO |
MAILING ADDRESS:
POST OFFICE BOX 172609
TAMPA, FLORIDA 33672-0609
December 6, 2007
VIA EDGAR AND FACSIMILE (202)772-9210
Mr. Jeffrey Riedler
Assistant Director
Division of Corporation Finance
Mail Stop 6010
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
| Re: | GeoPharma, Inc. |
| Registration Statement on Form S-3 Filed April 26, 2007 |
| Amendment No. 1 thereto filed June 5, 2007 |
| Amendment No. 2 thereto filed August 22, 2007 |
| File No. 333-142369 |
Dear Mr. Riedler:
On behalf of GeoPharma, Inc., we hereby request effectiveness of the above-referenced Registration Statement, effective as of 12:00, tomorrow, December 7, 2007, or as soon thereafter as is practicable. In connection therewith, we hereby acknowledge, on behalf of our client, 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 this action as a defense in any proceeding initiated by the Commission or any person under the federal securities Laws of the United States. |
Thank you in advance for your attention and cooperation with this matter. Should you have any questions or need additional information, please do not hesitate to contact me at (813) 227-2325.
Sincerely,
/s/ Julio C. Esquivel
Julio C. Esquivel
| cc: | C. Dore-Falcone |
