September 12, 2018

Richard W. Pascoe
Chief Executive Officer and Secretary
Apricus Biosciences, Inc.
11975 El Camino Real, Suite 300
San Diego, CA 92130

       Re: Apricus Biosciences, Inc.
           Registration Statement on Form S-4
           Filed August 31, 2018
           File No. 333-227166

Dear Mr. Pascoe:

       We have limited our review of your registration statement to those
issues we have
addressed in our comment.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comment applies to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to this comment, we may have additional comments.

Form S-4 Filed August 31, 2018

General

1.     We note that you have a pending request for confidential treatment
relating to Exhibits
       10.33, 10.34, and 10.35. Please be advised that we will not be in a
position to declare
       your registration statement effective until we resolve any issues
concerning the
       confidential treatment request.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
 Richard W. Pascoe
Apricus Biosciences, Inc.
September 12, 2018
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Jeffrey Gabor at 202-551-2544 or Erin Jaskot at
202-551-3442 with
any questions.



                                                           Sincerely,
FirstName LastNameRichard W. Pascoe
                                                           Division of
Corporation Finance
Comapany NameApricus Biosciences, Inc.
                                                           Office of Healthcare
& Insurance
September 12, 2018 Page 2
cc:       Jacob D. Steele, Esq.
FirstName LastName