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Akela Pharma Inc. | |
11400 Burnet Road, Suite 4010 | |
Austin, TX 78758 |
January 17, 2008
VIA EDGAR and FACSIMILE (202-772- 9217)
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-0404
Re: | Akela Pharma Inc. |
| Registration Statement on Form F-1/A |
| File No. 333-146684 |
Ladies and Gentlemen:
Pursuant to Rule 477 under the Securities Act of 1933, as amended, Akela Pharma Inc., a Canada company (the “Company”), hereby requests the withdrawal of its Registration Statement on Form F-1 (File No. 333-146684) initially filed with the Securities and Exchange Commission (the “Commission”) on October 12, 2007, as subsequently amended, together with all exhibits thereto. Due to unfavorable market conditions, the Company has determined that it is unable to proceed with the offering at this time. The Company has not sold any securities by means of the preliminary prospectus that forms a part of the Registration Statement.
Accordingly, the Company requests that the Commission issue an order granting the withdrawal of the Registration Statement, including all exhibits thereto, as soon as possible. The Company also requests that all fees paid to the Commission in connection with the filing of the Registration Statement be credited to the Company’s account with the Commission for future use.
The Company wishes to express its appreciation to the Staff of the Commission for its assistance and cooperation throughout the review and filing process.
Should you have any questions or require any additional information with respect to this request, please contact Barbara A. Jones at (617) 951-9096 or by facsimile at (617) 261-3175.
| Respectfully submitted, | |||
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| AKELA PHARMA INC. | |||
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| By: | /s/ ANDREW REITER |
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| Andrew Reiter | ||
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| Chief Financial Officer | ||
cc: |
| Paul Dudek, Director, Office of International Corporate Finance, SEC |
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| Jeffrey Riedler, Assistant Director, Division of Corporation Finance, SEC |
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| John Krug, Division of Corporation Finance, SEC |
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| Vanessa Robertson, Division of Corporation Finance, Office of Chief Accountant, SEC |
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| Leslie Gord, Esq., Gowling Lafleur Henderson LLP |
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