View:
Snell
& Wilmer L.L.P.
600
Anton
Boulevard
Suite
1400
Costa
Mesa, California 92626-7689
TELEPHONE:
(714) 427-7000
FACSIMILE:
(714) 427-7799
|
Mark
R. Ziebell
714.427.7402
mziebell@swlaw.com
|
August
27, 2007
|
Via
Federal Express
Division
of Corporate Finance
Securities
and Exchange Commission
100
F
Street, N.E.
Washington,
D.C. 20549
Mail
Stop
6010
Attn.:
Jeffrey P. Riedler, Assistant Director
|
RE:
|
Peregrine
Pharmaceuticals, Inc. (the
“Company”)
|
Schedule
14A
Filed
August 17, 2007
File
No. 1-32839
Dear
Mr.
Riedler:
Enclosed
please find three (3) copies of the Company’s Definitive Schedule 14A. By letter
dated August 23, 2007, the Securities and Exchange Commission (the “Commission”)
noted the following comment:
Proposal
3
Does
The Company Plan On Issuing Additional Shares, page 11
1. Please
clarify whether you currently have any plans to issue any of the shares that
would be authorized through this proposal. We note that you refer at the bottom
of page 11 to arrangements that are described in your Form 10-K. If you have
any
plans to issue shares, please describe the plans in this section of you filing
and state, if known, how many shares will be issued pursuant to each such plan.
After discussing all of the plans, state definitively that you have no other
plans other than the ones that you have described in this section of your
filing.
The
Company notes the Commission’s comment and has revised its disclosure on page 11
to delete the reference to arrangements that are described on its Form 10-K.
The
Company does not have any plans to issue any of the shares that would be
authorized through Proposal 3, and has revised its disclosure to so confirm.
Mr.
Jeffrey P. Riedler
August
27, 2007
Page
2
The
Company hereby acknowledges that:
|
●
|
the
Company is responsible for the adequacy and accuracy of the disclosure
in
the filing;
|
|
●
|
staff
comments or changes to disclosure in response to staff comments do
not
foreclose the Commission from taking any action with respect to the
filing; and
|
|
●
|
the
Company may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities
laws of the United States.
|
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