EXHIBIT 10.41 POLICY OF ENDO PHARMACEUTICALS HOLDINGS INC. RELATING TO INSIDER TRADING IN COMPANY SECURITIES AND CONFIDENTIALITY OF INFORMATION

EXHIBIT 10.41

POLICY OF ENDO PHARMACEUTICALS HOLDINGS INC.
RELATING TO INSIDER TRADING IN COMPANY
SECURITIES AND CONFIDENTIALITY OF INFORMATION

      The Board of Directors has adopted the following Policy which applies to all personnel (including directors and officers) of Endo Pharmaceuticals Holdings Inc. and its subsidiaries (collectively called the “Company”) arising from our legal and ethical responsibilities as a public company.

       1. Prohibition Against Trading on Undisclosed Material Information : If you are aware of material information relating to the Company which has not yet been available to the public for at least two full days (often called “inside information”), you are prohibited from trading in our securities, directly or indirectly, and from disclosing such information to any other persons who may trade in our securities. Any information, positive or negative, is “material” if it might be of significance to an investor in determining whether to purchase, sell or hold our securities. Information may be significant for this purpose even if it would not alone determine the investor’s decision. Examples include a potential business acquisition, internal information about revenues, earnings or other aspects of financial performance which departs in any way from what the market would expect based upon prior disclosures, important business developments (including FDA approval or nonapproval of one of our products), the acquisition or loss of major customer, or an important transaction. We emphasize that these examples are merely illustrative. When we refer to our “securities” we mean both the Company’s common stock and the Company’s warrants.

      Once material information is publicly announced, trading can occur after a lapse of two full trading days. Therefore, if an announcement is made before the commencement of trading on a Monday, an employee may trade in the Company’s stock or warrants starting on the Wednesday of that week, because two full trading days would have elapsed by then (all of Monday and Tuesday). If the announcement is made on Monday after trading begins, employees may not trade in the Company’s stock or warrants until Thursday. Please consult myself, Jeffrey R. Black or Caroline B. Manogue if you are uncertain when trading may commence following an announcement.

      The above prohibition against trading on inside information generally reflects the requirements of law as well as the Company’s Policy. As more fully discussed fully discussed below, a breach of this Policy probably will constitute a serious legal violations as well.

       2. Restricted Periods: In addition to the limitations set forth in Section 1 above, no personnel should trade any securities of the Company during periods that begin 10 trading days prior to the end of each of the Company’s fiscal quarters (including its fiscal year end) and ending two full trading days after the financial results for each quarter, or with respect to the fourth quarter for the full year, have been announced publicly (the “Restricted Period”). The Company’s fiscal quarters end on each March 31, June 30 and September 30 and its fiscal year end is December 31. The announcement date of the quarterly results varies, but occurs normally around the 45 ^th day following the end of the fiscal quarter. For example, you cannot trade any securities of the Company from June 15 ^th until August 18 ^th , two full trading days after the second quarter results are publicly announced. Notwithstanding the foregoing, personnel may sell any securities of the Company during a Restricted Period if such securities are sold pursuant to an effective registration statement on Form S-3 or Form S-4 or any successor form thereto on file with the U.S. Securities and Exchange Commission (an