July 18, 2019

Gerri A. Henwood
Chief Executive Officer
Recro Enterprises, Inc.
490 Lapp Road
Malvern, PA 19355

       Re: Recro Enterprises, Inc.
           Draft Registration Statement on Form 10
           Submitted June 24, 2019
           CIK No. 0001780097

Dear Ms. Henwood:

       We have reviewed your draft registration statement 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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form 10

Exhibit 99.1
Our Product Candidates, page 11

1.     We note that you received a second CRL from the FDA. Please revise to
briefly discuss
       the FDA's concerns and your plans to address such concerns to include
the anticipated
       timing and capital requirements necessary to execute such plans.
Our product candidates may cause adverse events, page 22

2.     We note your disclosure here that your "[c]linical studies conducted
with IV meloxicam
       and other product candidates have generated some AEs, and in some cases
serious adverse
       effects, or SAEs." We also note the Study REC-15-015 and Safety Study
sections on
 Gerri A. Henwood
FirstName LastNameGerri A. Henwood
Recro Enterprises, Inc.
Comapany NameRecro Enterprises, Inc.
July 18, 2019
July 18, 2019 Page 2
Page 2
FirstName LastName
         pages 80-81 reference the occurrence of certain SAEs. Please clarify
whether the SAEs
         were treatment-related. In addition, in all three sections, to the
extent either the SAEs
         were treatment-related or their cause remains undetermined, please
revise to disclose the
         serious adverse effects that were observed in the respective trials.
Unaudited Pro Forma Combined Financial Statements, page 62

3.       Adjustment (A) on page 65 gives effect to the $13 million in cash
funding that Recro
         plans to provide to Enterprises upon the completion of the Separation.
Tell us how you
         considered whether this adjustment was factually supportable for
purposes of including in
         pro forma financial statements.
Managements Discussion and Analysis of Financial Condition and Results of
Operations
Financial Overview
Results of Operations, page 69

4.       For each of the periods presented, please quantify each factor noted
for the increase and/or
         decrease in research and development and general and administrative
expenses.
Our Other Pipeline Candidates, page 82

5.       For each product candidate, please revise to discuss their development
status in greater
         detail.
Intellectual Property, page 83

6.       We note under the license agreement with Cornell that you are
obligated to pay an annual
         license maintenance fee and an annual minimum royalty amount. Please
revise to disclose
         a general range of these payment amounts.
7.       We note under the license agreement with Orion that you may be
obligated to pay
         Orion lump sum payments upon the achievement of certain development
and commercial
         milestones. Please revise to disclose the aggregate amount of these
payments.
Description of Enterprises Capital Stock, page 130

8.       We note your disclosure that the summaries are qualified in their
entirety by reference, in
         part, to the applicable provisions of the PBCL. It is not appropriate
to qualify your
         disclosure by reference to information that is not included in the
filing or filed as an
         exhibit. Please revise accordingly. Please refer to Securities Act
Rule 411(a).
Notes to the Combined Financial Statements
(4) Acquisitions
Gainsville Facility and Meloxicam, page F-30

9.       With regards to the Warrant Agreement with Alkermes, you disclose that
the warrant
 Gerri A. Henwood
Recro Enterprises, Inc.
July 18, 2019
Page 3
         associated with the Gainsville transaction remains on the Recros
Consolidated Balance
         Sheets as the equity plan is held at the corporate level. Please
clarify if you have
         allocated any portion of the warrant to the company, and explain why
or why not.
       You may contact Sasha Parikh at 202-551-3627 or Kevin Vaughn at
202-551-3494 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Donald Field at 202-551-3680 or Dietrich King at 202-551-8071 with any
other
questions.



FirstName LastNameGerri A. Henwood                           Sincerely,
Comapany NameRecro Enterprises, Inc.
                                                             Division of
Corporation Finance
July 18, 2019 Page 3                                         Office of
Healthcare & Insurance
FirstName LastName