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                             December 12, 2022

       Stephen P. Carey
       Senior Vice President, Finance and Chief Financial Officer
       ANI Pharmaceuticals, Inc.
       210 Main Street West
       dette , Minnesota 56623

                                                        Re: ANI
Pharmaceuticals, Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2021
                                                            Filed March 15,
2022
                                                            Form 8-K furnished
August 8, 2022
                                                            File No. 001-31812

       Dear Stephen P. Carey:

              We have reviewed your December 5, 2022 response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

            After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       November 1, 2022 letter.

       Form 8-K furnished November 9, 2022

       Table 3: Adjusted non-GAAP EBITDA Calculation and US GAAP to Non-GAAP
       Reconciliation, page Table3

   1.                                                   We note your non-GAAP
adjustment for In-process research and development in the three
                                                        months ended September
30, 2022. We believe the adjustment is inconsistent with
                                                        Question 100.01 of the
Non-GAAP Financial Measures Compliance and Disclosure
                                                        Interpretation. Please
confirm to us you will no longer include the adjustment in any non-
                                                        GAAP financial measure
presented in accordance with Item 10(e) of Regulation S-K or
                                                        Regulation G.
 Stephen P. Carey
FirstName LastNameStephen
ANI Pharmaceuticals, Inc. P. Carey
Comapany12,
December   NameANI
              2022 Pharmaceuticals, Inc.
December
Page 2    12, 2022 Page 2
FirstName LastName
Correspondence dated December 5, 2022

Non-GAAP Financial Measures, page 6

2.       You state in response to comment 1 that in connection with the
November 2021
         acquisition of Novitium Pharma LLC you acquired a fourth
pharmaceutical manufacturing
         plant. During the integration of Novitium you determined that three
manufacturing plants
         would support your manufacturing capacity needs and you thus decided
to close the
         Canada plant and move the majority of production being undertaken in
Canada to the
         remaining U.S. based manufacturing plants. As the operations appear to
be continuing,
         although at a different manufacturing facility, it is unclear why it
is appropriate to include
         a non-GAAP adjustment for the Canada operations. Please confirm you
will revise your
         presentation in the future, or clarify to us further why you believe
revenues and expenses
         relating to products previously manufactured at the Canada facility
will not continue at the
         new manufacturing facility.
3.       We acknowledge your response to comment 2. Although you are no longer
adjusting for
         Cortrophin pre-launch charges and sales and marketing expenses, we
continue to believe
         that the non-GAAP adjustments in prior periods are not appropriate
since these costs are
         normal costs incurred in your business to achieve FDA approval,
regardless of whether or
         not regulatory approval is ultimately obtained. Please confirm you
will revise to eliminate
         these adjustments in future filings or tell us why these costs are
different from costs
         incurred by other companies in your industry to obtain regulatory
approval.
       You may contact Ibolya Ignat at 202-551-3636 or Mary Mast at
202-551-3613 with any
questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of Life
Sciences