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Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                   February 23, 2009   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 February 13, 2009 to our comment
letter dated December 29, 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 29,
2008.  In your response, you draw a distinction between the general relationships
you currently have with each of the Nati onal Institutes of H ealth (NIH) and the
University of Maryland, Baltimore County (UMBC), which you consider to be “key strategic alliances” and the actual  underlying license agreements with each
institution which you do not consider to be  material to your company.  However,
the disclosure presented in your 2007 Form

Dr. Raafat E.F. Fahim, Ph.D.
Nabi Biopharmaceuticals
February 23, 2009 Page 2
10-K does not clearly make this distinction.  Please revise your disclosure appropriately in your 2008 Form 10-K to explain that you consider the
relationships with NIH and UMBC to be key strategic alliances and the reasons
why you consider these relationships to be  important.  Please also revise your
disclosure to clarify that the related license agreements  are not material to your
business and you are not substantially de pendent upon them or, if you determine
that the license agreements are material  to your business, please disclose the
material terms of each of these license ag reements and file them as exhibits to
your 2008 Form 10-K.  Please provide us w ith a copy of your proposed disclosure
regarding your relationship with NI H and UMBC and the related license
agreements.  After reviewing your proposed  disclosure, we may have additional
comments.

*    *    *    *

Please revise 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.

Dr. Raafat E.F. Fahim, Ph.D.
Nabi Biopharmaceuticals February 23, 2009 Page 3
 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
  cc: James E. Dawson, Esq.
Nutter, McClennen & Fish LLP World Trade Center West  155 Seaport Boulevard Boston, MA 02210