Exhibit 16.1




February 6, 2006


Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

Gentlemen:

We have read Item 4.01 of Form 8-K/A dated February 6, 2006, of
A.P. Pharma, Inc. and are in agreement with the statements
contained in the first and second sentences of the first
paragraph, the second and third paragraphs, the first sentence of
the fourth paragraph, and the fifth paragraph on page two
therein. We have no basis to agree or disagree with the other
statements of the registrant contained therein.


                             /s/Ernst & Young LLP