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Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                   December 29, 2008   Dr. Raafat E.F. Fahim, Ph.D. President and Chief Executive Officer Nabi Biopharmaceuticals 12276 Wilkins Avenue Rockville, MD 20852
Re: Nabi Biopharmaceuticals
 Form 10-K for the Year Ended December 31, 2007  Filed February 28, 2008  File No. 000-04829

Dear Dr. Fahim:

We have reviewed your response letter dated December 17, 2008 to our comment
letter dated December 4, 2008 and have the following comment.
Where indicated, we think you should revise your Form 10-K in response to this
comment.  If you disagree, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  In  our comment, we ask you to provide us with
information so we may better understand your  disclosure.  After reviewing this
information, we may raise additional comments.   Please understand that the purpose of our re view 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 comment 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 15.  Exhibits, page 60

1. We note your response to comment 1 of our comment letter dated December 4,
2008.  In your response, you state that you do not believe that the license
agreements with each of the National Institutes of Health (NIH) and the
University of Maryland, Baltimore County (UMBC) are material to your company.  It appears that this response is  inconsistent with your disclosure in
the Form 10-K where you refer to these license agreements as “key strategic
alliances” (page 6) and identify them as “material strategic alliances” in your

Dr. Raafat E.F. Fahim, Ph.D.
Nabi Biopharmaceuticals December 29, 2008 Page 2
 notes to the financial statements (pages  54-55).  Therefore,  we are reissuing
comment 1 in part.  Please f ile each of these license ag reements as an exhibit to
your Form 10-K.

*    *    *    *

Please amend your Form 10-K and respond to this comment within 10 business
days or tell us when you will provide us with a response.  Please furnish a cover letter
with your amendment that keys your response to our comment and provide any requested information.  Detailed letters greatly facilitate our review.  Please file your letter on
EDGAR under the form type label CORRESP.   We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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 co mments, 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
filing;
• 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comment on your filing.
Please contact Nandini Acharya, Staff Atto rney at (202) 551-3495 or me at (202)
551-3715 with any questions.

Sincerely,

Jeffrey P. Riedler Assistant Director