ZS Pharma, Inc.
508 Wrangler Drive, Suite 100
Coppell, Texas 75019
June 13, 2014
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-6010
| Attention: | Jeffrey P. Riedler, Assistant Director | |
| Scott Wuenschell | ||
| Joel Parker | ||
| Christina De Rosa | ||
| Dan Greenspan | ||
| Re: | ZS Pharma, Inc. | |
| Registration Statement on Form S-1 (Registration No. 333-195961) | ||
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form S-1 (File No. 333-195961) (the “Registration Statement”) of ZS Pharma, Inc. (the “Company”). We respectfully request that the Registration Statement become effective as of 1:00 p.m., Washington, D.C. time, on June 17, 2014, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Baker Botts L.L.P., by calling Mollie Duckworth at (512) 322-2551.
The Company acknowledges the following:
| • | should the Securities and Exchange Commission (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 staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Thank you for your assistance in this matter.
| Very truly yours, | ||
| ZS PHARMA, INC. | ||
| By: | /s/ Todd Creech | |
| Todd Creech | ||
| Chief Financial Officer | ||
| cc: | Mollie Duckworth, Baker Botts L.L.P. |
Mike Bengtson, Baker Botts L.L.P.
Alan F. Denenberg, Davis Polk & Wardwell LLP
2
