August 9, 2005


Mail Stop 6010

Lawrence M. Christian
Chief Financial Officer
Antares Pharma, Inc.
707 Eagleview Boulevard, Suite 414
Exton, Pennslvania 19341

Re:	Antares Pharma, Inc.
	Post Effective Amendment on Form S-3
      Filed July 22, 2005
	         File No. 333-109114
Dear Mr. Christian
      We have limited our review of your filing to those issues we
have addressed in our comments.  Where indicated, we think you
should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Facing Page
1. If your filing is based on Rule 429, please say so and identify
the appropriate registration statement in accordance with the
requirements of Rule 429(b).

Prospectus
2. We note your reference on page 18 to information in previous
prospectuses.  Information in prospectuses may not be incorporated
by
reference to a prior prospectus.  Instead, you must file a
prospectus
that includes all of the information that would be required in a
prospectus relating to all offerings that the rule 429 prospectus
covers, including a complete, current selling shareholders table.

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to a company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      Before the amended registration statement is declared
effective
pursuant to Section 8 of the Securities Act, the company should
provide us with a letter, acknowledging that:
?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
?	the action of the Commission or the staff, 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
?	the company may not assert staff comments and 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.
	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.
      You may contact Jay Mumford at (202) 824-5348 or me at (202)
942-3617 with any other questions.
      Sincerely,




							Russell Mancuso
							Branch Chief

cc:	Morris M. Sherman, Esq.