SEC – ‘UPLOAD’ from 8/25/05 re: Nymox Pharmaceutical Corp – ‘LETTER’

On:  Thursday, 8/25/05, at 2:24pm ET   ·   Private-to-Public:  Filing ¶  –  Release Delayed to:  8/28/06   ·   Accession #:  0-5-44142

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Delayed-Release Comment or Other Letter from the SEC
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: LETTER      Comment or Other Letter from the SEC                   3±    14K 


Via Facsimile and U.S. Mail                                                     
Mail Stop 6010                                                                  

July 22, 2005                                                                   

Mr. Roy Wolvin                                                                  
Chief Financial Officer                                                         
Nymox Pharmaceutical Corporation                                                
9900 Cavendish Blvd., Suite 306                                                 
St. Laurent, Quebec  H4M 2V2                                                    
CANADA                                                                          

Re:     Nymox Pharmaceutical Corporation                                        
Form 20-F for the Fiscal Year Ended December 31, 2004           
Filed June 30, 2005                                             
File No. 001-12033                                              

Dear Mr. Wolvin:                                                                

We have limited our review to only your financial statements    
and                                                                             
related disclosures and do not intend to expand our review to                   
other                                                                           
portions of your document.  In our comments, we ask you to provide              
us                                                                              
with information so we may better understand your disclosure.                   
Please                                                                          
be as detailed as necessary in your explanation.  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 on any other                   
aspect                                                                          
of our review.  Feel free to call us at the telephone numbers                   
listed                                                                          
at the end of this letter.                                                      

Item 5.  Operating and Financial Review and Prospects, page 26                

1. Please refer to the Division of Corporation Finance "Current                 
Issues and Rulemaking Projects Quarterly Update" under section                  
VIII -                                                                          
Industry Specific Issues - Accounting and disclosure by Companies               
Engaged in Research and Development Activities. You can find it at              
the following website address:                                                  
http://www.sec.gov/divisions/corpfin/cfcrq032001.htm.                           

Please provide us the following information in disclosure-type                  
format                                                                          
to help us evaluate the adequacy of your disclosure for each of                 
your                                                                            
major research and development projects:                                        

a. The current status of the project;                                           

b. The costs incurred during each period presented and to date on               
each project;                                                                   

c. The nature, timing and estimated costs of the efforts necessary              
to                                                                              
complete each project;                                                          

d. The anticipated completion dates of each project;                            

e. The risks and uncertainties associated with completing                       
development                                                                     
on schedule, and the consequences to operations, financial                      
position                                                                        
and liquidity if each project is not completed timely; and finally              

f. The period in which material net cash inflows from significant               
projects are expected to commence for each project.                             

Regarding b., if you do not maintain any research and development               
costs by project, please state that fact and explain why                        
management                                                                      
does not maintain and evaluate research and development costs by                
project.  In this regard, please provide other quantitative or                  
qualitative disclosure that indicates the amount of the company`s               
resources being used on the project.                                            

Regarding c. and d., please state the amount or range of estimated              
costs and timing to complete the phase in process and each future               
phase.  To the extent that information is not estimable, please                 
state                                                                           
those facts and circumstances indicating the uncertainties that                 
preclude you from making a reasonable estimate.                                 

Please respond to these comments within 10 business days or         
tell us when you will provide us with a response.  Please furnish               
a                                                                               
letter that keys your responses to our comments and provide the                 
requested information.  Detailed letters greatly facilitate our                 
review.  Please file your letter on EDGAR under the form type                   
label                                                                           
CORRESP.  Please understand that we may have additional comments                
after reviewing your 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                 
filings include all information required under the Securities                   
Exchange Act of 1934 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.                                     

In connection with responding to our comments, please           
provide,                                                                        
in your letter, a statement from the company acknowledging that                 

* the company is responsible for the adequacy and accuracy of the               
disclosure 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 filing; and                                                      

* the company 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.                                   

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 our review of your filing or in              
response to our comments on your filing.                                        

You may contact Oscar M. Young, Jr., Senior Staff                   
Accountant,                                                                     
at (202) 551-3622 if you have questions regarding the comments.                 
Please contact me at (202) 551-3679 with any other questions.                   

Sincerely,                                                                      

Jim B. Rosenberg                                                                
Senior Assistant Chief                                                          
Accountant                                                                      
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Roy Wolvin                                                                      
Nymox Pharmaceutical Corporation                                                
July 22, 2005                                                                   
Page 3                                                                          

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘UPLOAD’ Filing		Date		Other Filings
Release Delayed to:		8/28/06		CORRESP,  UPLOAD
Filed on:		8/25/05		UPLOAD
		7/22/05		UPLOAD
		6/30/05		20-F,  6-K,  UPLOAD
		12/31/04		20-F,  20-F/A,  6-K
				List all Filings

1 Previous Filing that this Filing References

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

 6/30/05  Nymox Pharmaceutical Corp.        20-F       12/31/04    5:988K                                   Foley & Lardner/FA