Christopher J. Mugel (804) 771.5787 cjmugel@kaufcan.com | Kaufman & Canoles, P.C. Three James Center, 12th Floor 1051 East Cary Street Richmond, VA 23219
Mailing Address Post Office Box 27828 Richmond, VA 23261
T (804) 771.5700 F (804) 771.5777
kaufCAN.com |
October 27, 2010
Jeffrey P. Riedler, Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 3561
100 F Street, N.E.
Washington, D.C. 20549
Re: | Tibet Pharmaceuticals, Inc. |
Amendment No. 6 to Registration Statement on Form S-1
Filed on October 27, 2010
File No. 333-166854
Dear Mr. Riedler:
On behalf of Tibet Pharmaceuticals, Inc. (“TBET”), we are submitting herewith TBET’s Amendment No. 6 to its Registration on Form S-1.
Amendment No. 6 primarily reflects changes necessitated by the placement agent’s decision not to include placement agent warrants in the offering terms.
TBET is eager to complete the registration process. Thank you in advance for your assistance in reviewing this response and Amendment No. 5 to the Registration Statement on Form S-1. Should you have any questions with respect to the above responses, please contact me.
Sincerely,
/s/ Christopher J. Mugel
Christopher J. Mugel
Disclosure Required by Internal Revenue Service Circular 230: This communication is not a tax opinion. To the extent it contains tax advice, it is not intended or written by the practitioner to be used, and it cannot be used by the taxpayer, for the purpose of avoiding tax penalties that may be imposed on the taxpayer by the Internal Revenue Service.