September 7, 2018

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

       Re: ANI Pharmaceuticals, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed February 27, 2018
           File No. 001-31812

Dear Mr. Carey:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment we ask you to
provide us with
information so we may better understand your disclosure.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to the comment, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2017

5. Intangible Assets
Definite-lived Intangible Assets
Acquisition of New Drug Applications and Product Rights, page 89

1.    You recorded the February and December 2017 acquisitions as asset
acquisitions. Please
      tell us, for each acquisition, why you believe the acquisitions are not
required to be
      recorded as an acquisition of a business pursuant to ASU 2017-01. In this
regards, please
      specifically address the following:
        As it appears you acquired both tangible and intangible assets in the
February
           acquisitions and the December acquisition appears to relate to
assets with significantly
           different risks, please confirm our understanding that the
acquisitions did not meet the
           "practical screen" in ASC 805-10-55-5A through 55-5C as the term is
used in ASC
 Stephen P. Carey
ANI Pharmaceuticals, Inc.
September 7, 2018
Page 2
             805-10-55-5. Refer also to the example in ASC 805-10-55-68.
             Please address each of the criteria in ASC 805-10-55-5E in
determining whether or not
             a substantive process was acquired, that together with the input
acquired, significantly
             contribute to the ability to create outputs.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Vanessa Robertson at 202-551-3649 or Mary Mast at
202-551-3613
with any questions.



FirstName LastNameStephen P. Carey                             Sincerely,
Comapany NameANI Pharmaceuticals, Inc.
                                                               Division of
Corporation Finance
September 7, 2018 Page 2                                       Office of
Healthcare & Insurance
FirstName LastName