SecProbe.io

December 30, 2010
 Raafit E. F. Fahim, Ph.D. Chief Executive Officer Nabi Biopharmaceuticals 12276 Wilkins Avenue Rockville, MD 20852
Re: Nabi Biopharmaceuticals
Form 10-K for the Fiscal Year Ended December 26, 2009 Form 10-Q for the Quarterly Period Ended September 25, 2010
  File No. 000-04829

Dear Mr. Fahim:
 We have limited our review of your filings to  those issues we have addressed in our
comment.  In our comment, we ask you to provi de us with information so we may better
understand your disclosure.

Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  Where a comment
requests you to revise disclosu re, the information you provide s hould show us what the revised
disclosure will look like and identify the annual or quarterly filing, as applicable, in which you
intend to first include it.  If you do not believe our comment  applies to your facts and
circumstances, please tell us why in your res ponse.  Please furnish us a letter on EDGAR under
the form type label CORRESP that keys your response to our comment.

After reviewing the information you provide in  response to our comment, we may have
additional comments and/or requ est that you amend your filings.
 Form 10-Q for the Quarterly Period Ended September 30, 2010

 Notes to Condensed Consolidated Financial Statements

Note 9 Licenses and Revenue Arrangements, page 13

1. Regarding your PentaStaph and NicVAX ag reements, you disclose that you are
recognizing the upfront payments from GSK ra tably over the period of  your performance
obligations contained in the agreement, including participation on a joint steering
committee.  Please revise your disclosure to  specifically identif y the period over which
you are recognizing the upfront payments.
              We urge all persons who are res ponsible for the accuracy and adequacy of the disclosure
in the filings to be certain that the filings incl ude the information the Secu rities Exchange Act of

Raafit E. F. Fahim, Ph.D.
Nabi Biopharmaceuticals December 30, 2010 Page 2

 1934 and all applicable Exchange Act rules requir e.  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 responding to our comments, please provide a written 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 filings; 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.

You may contact Staci Shannon, Staff Account ant, at (202) 551-3374 or Joel Parker,
Accounting Branch Chief, at (202) 551-3651 if you have questions regarding the comment.  In
this regard, do not hesitate to contact me  at (202) 551-3679 with any other questions.

Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant