KEDEM PHARMACEUTICALS INC.
409 Granville Street, Suite 1023
Vancouver, British Columbia
Canada V6C 1T2
Tel: (604) 324-4844
Fax: (604) 324-4845
www.kedempharma.com
March 20, 2013
VIA EDGAR
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
| Attention: | Heather Clark, Staff Accountant |
Dear Ms. Clark:
| Re: | Kedem Pharmaceuticals Inc. |
I am the Chief Executive Officer of Kedem Pharmaceuticals Inc. (the “Company”) and submit this letter pursuant to a comment letter from the Securities and Exchange Commission (the “SEC”) dated February 11, 2013. My response is as follows:
| 1. | Please amend your Form 8-K to ensure that that date in the exhibit 16 letter references the date on the cover page of the amended 8-K. In this regard, we note that the exhibit 16 letter refers to the 8-K dated February 6, 2013 and the 8-K filed is dated January 14, 2013. |
Response: The Company does not believe that an amendment to the Form 8-K is necessary in the circumstances because the reference to the 8-K in the exhibit 16 letter is correct. For clarity, although the date of the earliest event reported on the Form 8-K is January 14, 2013 (as noted on the cover page), the actual date of the 8-K is February 6, 2013 (as noted on the signature page). This matches the date of the exhibit 16 letter.
* * * * *
On behalf of the Company, I acknowledge that:
| ● | the Company is responsible for the adequacy and accuracy of the disclosure in the filing; |
| ● | staff comments or changes to disclosure in response to staff comments do not foreclose the SEC from taking any action with respect to the filing; and |
| ● | the Company may not assert staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States. |
Please do not hesitate to contact me if you have any further questions or comments.
Yours truly,
/s/ Christian Bezy
Christian Bezy
Chief Executive Officer
