February 11, 2009

Via EDGAR

Jeffrey Riedler, Esq.

Suzanne Hayes, Esq.

Nandini Acharya, Esq.

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Mail Stop 6010

Re: Cellegy Pharmaceuticals, Inc. Registration Statement on Form S-4/A Filed January 12, 2009 File No. 333-155322

Dear Mr. Rielder, Ms. Hayes and Ms. Acharya:

As requested, Cellegy Pharmaceuticals, Inc. (“Cellegy” or the “Company”) is enclosing materials referenced in our letter previously sent to you dated February 10, 2009 in response to comments raised in the Staff’s letter to Cellegy dated February 9, 2009 regarding your review of Amendment No. 2 to the above-referenced registration statement on Form S-4/A filed by Cellegy on February 4, 2009 relating to its proposed merger transaction with Adamis Pharmaceuticals, Inc. (“Adamis”) and Cellegy’s annual meeting of stockholders.

Enclosed is (1) a copy of the listing from FDA's Approved Drug Products List with Therapeutic Equivalence Evaluations (the FDA's "Orange Book"); (2)  a copy of the listing from FDA's National Drug Code Directory; and (3) a copy of the FDA's Compliance Policy Guide.

In connection with responding to your comments, the undersigned acknowledges that:

· Cellegy is responsible for the adequacy and accuracy of the disclosures in the filings;

· Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and

· Cellegy 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.

You may contact me at (215) 529-6084, or our attorney Kevin Kelso, at Weintraub Genshlea Chediak, at (916) 558-6110, if you have any questions regarding the above responses to your comments.

Sincerely,

/s/ Robert J. Caso                                  

Robert J. Caso, Chief Financial Officer