Edwards Angell Palmer & Dodge LLP

525 Okeechobee Boulevard, Suite 1600 

West Palm Beach, FL  33401  

561.833.7700   fax 561.655.8719  

eapdlaw.com

Leslie J. Croland

561.833 .7700

fax 561.655.8719

lcroland@eapdlaw.com

December 21, 2010

VIA EDGAR

Ms. Erin Jaskot, Staff Attorney

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

RE:	CTD Holdings, Inc.
	Form 10-K for the Fiscal Year ended December 31, 2009
	Forms 10-Q for the Fiscal Quarters ended March 31, 2010, June 30, 2010 and September 30, 2010
	File No. 000-25466

Dear Ms. Jaskot:

This letter is written on behalf of CTD Holdings, Inc. (the “Company”) in connection with your December 13, 2010 comment letter.  The Company is unable to respond to the comment letter within the time period requested because (i) the Company has a limited staff, (ii) the Company’s office is closed and the staff is on vacation for two weeks, and (iii) the Company requires additional time to adequately address the comments in the staff’s comment letter. The Company anticipates that it will respond to the comment letter by January 26, 2011.

If you require any additional information, kindly contact me at (561) 833-7700.

Sincerely,

/s/ Leslie J. Croland

Leslie J. Croland

Cc:   C.E. Rick Strattan, Chief Executive Officer