3000 Two Logan Square
Eighteenth and Arch Streets
Philadelphia, PA 19103-2799
215.981.4000
Fax 215.981.4750
Steven J. Abrams
direct dial: 215.981.4241
direct fax: 866.422.3671
abramss@pepperlaw.com
March 3, 2015
CONFIDENTIAL SUBMISSION
VIA EDGAR
Draft Registration Statement | Confidential Submission Pursuant to |
Re: | Collegium Pharmaceutical, Inc. Confidential Submission of Draft Registration Statement on Form S-1 |
Ladies and Gentlemen:
On behalf of Collegium Pharmaceutical, Inc., a Virginia corporation (the “Company”), and in connection with the confidential submission of its draft registration statement on Form S-l (the “Registration Statement”) on the date hereof, we hereby confidentially submit the draft Registration Statement pursuant to Title I, Section 106 under the Jumpstart Our Business Startups Act (the “JOBS Act”) and Section 24(b)(2) of the Securities Exchange Act of 1934, as amended, for non-public review by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) prior to the public filing of the Registration Statement.
Pursuant to Title I, Section 101 of the JOBS Act, the Company is an “emerging growth company” that had total annual gross revenues of less than $1.0 billion during its most recently completed fiscal year ended December 31, 2014. Therefore, the Company is permitted to make this confidential submission of the Registration Statement for review by the Staff, provided that the Registration Statement and all amendments thereto shall be publicly filed with the Commission not later than 21 days before the date on which the Company commences a “road show,” as such term is defined in Title 17, Section 230.433(h)(4) of the Code of Federal Regulations.
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www.pepperlaw.com
Securities and Exchange Commission
Page 2
March 3, 2015
Please direct all notices, comments and communications with respect to this confidential submission to each of the following:
| Collegium Pharmaceutical, Inc. Attention: Paul Brannelly Suite 800 Canton, MA 02021 Telephone: 781.713.3699 |
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with a copy to: | Pepper Hamilton LLP Eighteenth and Arch Streets Philadelphia, PA 19103 Telephone: 215.981.4241 |
Please direct any questions regarding this filing to me at 215.981.4241.
| Very truly yours, |
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| /s/ STEVEN J. ABRAMS |
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| Steven J. Abrams |