November 2, 2018

Via E-mail
Michael J. Aiello, Esq.
Weil, Gotshal & Manges LLP
767 Fifth Avenue
New York, NY 10153

       Re:    Corium International, Inc.
              Schedule TO-T
              Filed October 26, 2018 by Gurnet Merger Sub, Inc. et. al
              File No. 5-88092

Dear Mr. Aiello:

      We have limited our review of the above filing to those issues we have
addressed in our
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand the disclosure.

       Please respond to this letter by amending the filing or providing the
requested
information. If you do not believe our comments apply to the filing persons'
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

        After reviewing any amendment to the filing and the information you
provide in response
to these comments, we may have additional comments. All defined terms used in
this letter have
the same meaning as in the Offer to Purchase, unless otherwise indicated.

Offer to Purchase

1.     Please revise the Schedule TO to include Gurnet Point L.P. on the
signature page. See
       Schedule TO's Instruction to Signature.

2.     Please provide us with a legal analysis as to whether the contingent
value rights are
       securities, the offer and sale of which should be registered under the
Securities Act of
       1933. In preparing your response, it may be helpful to provide your
analysis of prior staff
       no-action letters on this topic in support of your position.

3.     Please provide us with an analysis as to how the offer complies with the
prompt payment
       provisions of Exchange Act Rule 14e-1(c) and the disclosure requirements
of Item 1004
       of Regulation M-A, given the deferred nature of any contingent
consideration and the
       uncertainty of the total consideration to be paid to security holders,
respectively. In your
 Michael J. Aiello, Esq.
Weil, Gotshal & Manges LLP
November 2, 2018
Page 2

       analysis, please address whether the rights that security holders
receive would be
       considered enforceable as of the close of the offer under state law.

4.     Given the statement on page 15 that "[w]e were organized solely in
connection with the
       Offer and the Merger and, prior to the Offer Expiration Time, will not
carry on any
       activities other than in connection with the Offer and the Merger
[and]...through Gurnet,
       we will have sufficient funds available to purchase all Shares validly
tendered (and not
       withdrawn) in the Offer..." please provide us with a legal analysis that
explains the basis
       for the position that the financial condition of Gurnet is immaterial to
a shareholder's
       decision whether or not to participate in the tender offer.

                                              *   *   *

        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

       Please contact me at (202) 551-3444 with any questions.

                                                            Sincerely,

                                                            /s/ Perry J. Hindin

                                                            Perry J. Hindin
                                                            Special Counsel
                                                            Office of Mergers
and Acquisitions