Snell
& Wilmer LLP
600 Anton Bouleveard
Suite 1400
Costa Mesa, California 92626-7689
TELEPHONE: (714) 427-7000
FACSIMILE: (714) 427-7799
600 Anton Bouleveard
Suite 1400
Costa Mesa, California 92626-7689
TELEPHONE: (714) 427-7000
FACSIMILE: (714) 427-7799
|
Mark
R. Ziebell
714.427.7402
mziebell@swlaw.com
|
September
20, 2005
|
Via
Federal Express
Division
of Corporate Finance
Securities
and Exchange Commission
450
Fifth
Street, N.W.
Washington,
D.C. 20549
Mail
Stop
6010
Attn.:
Jeffrey P. Riedler, Assistant Director
|
RE:
|
Peregrine
Pharmaceuticals, Inc. (the “Company”)
|
|
Registration
Statement on Form S-3
|
|
|
File
No. 333-128322
|
Dear
Mr.
Riedler:
Enclosed
please find three (3) copies of the Pre-Effective Amendment No. 1 (the
“Amendment”) to the Company’s Registration Statement on Form S-3 filed September
14, 2005, File Number 333-128322 (the “Registration Statement”). By letter dated
September 19, 2005, the Securities and Exchange Commission (the “Commission”)
noted the following comment:
1. We
note the filing does not include the signature of your principal accounting
officer and principal financial officer. Please include these signatures in
your
amended Form S-3. If Paul J. Lytle serves in these capacities, his signature
should be captioned as such in your amended filing. See Instructions 1 and
2 to
the Signatures section of Form S-3.
The
Company notes the Commission’s comment and has revised the signature page to
properly identify Mr. Lytle as the Company’s principal accounting officer and
principal financial officer.
Mr.
Jeffrey P. Riedler
September
20, 2005
Page
2
If
you
have any questions, please do not hesitate to give me a call at (714)
427-7402.
| Very truly yours, | |||
| Snell & Wilmer | |||
| /s/ MARK R. ZIEBELL | |||
| Mark R. Ziebell | |||
MRZ:rp