MACROCHEM CORPORATION 40 Washington Street, Suite 220 Wellesley Hills, MA 02481 Telephone: (781) 489-7310 Fax: (781) 489-7311 May 2, 2007 U.S. Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, NW Washington, D.C. 20549 Re: MacroChem Corporation Request to Withdraw Amendment to Registration Statement Registration No. 333-132864 Dear Ladies and Gentlemen: This letter is hereby submitted to notify the Securities and Exchange Commission (the "SEC") of an inadvertent filing submission error made by MacroChem Corporation (the "Company"). On April 30, 2007, the Company filed Amendment No. 1 to Form S-1 (File No. 333-132864) ("Amendment No. 1") with the SEC using the incorrect EDGAR submission type, "S-1/A" (i.e., Pre-Effective Amendment), when it intended to use EDGAR submission type "POS AM" (i.e., Post-Effective Amendment). Pursuant to Rule 477(a) of the Securities Act of 1933, as amended, the Company hereby requests the withdrawal of the Amendment No. 1 filed on April 30, 2007. Please be advised that no securities were sold under Amendment No. 1. Please note that on May 1, 2007, the Company re-filed Post-Effective Amendment No. 1 to Form S-1 (File No. 333-132864) using the correct "POS AM" EDGAR submission type, and thus the May 1, 2007 filing is not requested to be withdrawn. Please direct any questions you may have with respect to this filing to Dwight W. Quayle at Ropes & Gray LLP (617-951-7000). Best regards, /s/ Bernard Patriacca Bernard Patriacca Chief Financial Officer