July 18, 2005
VIA FAX AND EDGAR
Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549
Attention: Jeffrey P. Riedler, Assistant Director
Fax Number: (202) 942-9533
Re: Adams Respiratory Therapeutics, Inc.
Registration Statement on Form S-1 (File No. 333-123585)
Acceleration Request
Ladies and Gentleman:
Adams Respiratory Therapeutics, Inc. (the "Company"), pursuant to
Rule 461 under the Securities Act of 1933, as amended, hereby requests the
Commission to accelerate the effective date of the above-referenced Registration
Statement and declare the Registration Statement, as then amended, effective as
of 2:00 p.m., eastern daylight savings time, on Wednesday, July 20, 2005, or as
soon thereafter as practicable. The Company also requests the Commission to
specifically confirm such effective date and time to the Company in writing.
The Company acknowledges that (i) should the Commission or the staff
of the Commission, acting pursuant to delegated authority, declare the filing
effective, such declaration does not foreclose the Commission from taking any
action with respect to the filing; (ii) the action of the Commission or the
staff of the Commission, acting pursuant to delegated authority, in declaring
the filing effective, does not relieve the Company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and (iii) the
Company may not assert the declaration of effectiveness as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
Please contact J. Mark Ray of Alston & Bird LLP with any questions or
comments at 404-881-7739. Thank you for your assistance with this filing.
Sincerely yours,
ADAMS RESPIRATORY THERAPEUTICS, INC.
By: /s/ Walter E. Riehemann
---------------------------------
Walter E. Riehemann
Executive Vice President
and Secretary
cc: J. Mark Ray, Alston & Bird LLP