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SEC Company Response from XOMA Royalty Corp (CIK 0000791908) (XOMA) — May 4, 2005

XOMA Royalty Corp (CIK 0000791908)
Date: May 4, 2005 · CIK: 0000791908 · Accession: 0000950162-05-000494

Regulatory Compliance Offering / Registration Process Capital Structure

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File numbers found in text: 333-123438

Date
May 4, 2005
Author
Christopher J. Margolin
Form
CORRESP
Company
XOMA Royalty Corp (CIK 0000791908)

Letter

Re: XOMA Ltd. Registration Statement on Form S-3 File No. 333-123438 Filed March 18, 2005, as amended April 28, 2005

May 4, 2005

Securities and Exchange Commission Judiciary Plaza 450 Fifth Street, N.W. Washington, D.C. 20549

Attention: Michael Reedich Division of Corporation Finance

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, the undersigned, being the issuer of securities to which the referenced Registration Statement relates, respectfully requests that the effectiveness of said Registration Statement be accelerated so that it will become effective at 10:00 A.M. on May 6, 2005 or as soon thereafter as practicable.

The disclosure in the filing is the responsibility of the Company. The Company acknowledges that should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing. The Company further acknowledges that the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosures in the filing.

The Company represents to the Commission that it will not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

<PAGE>

-2-

Very truly yours,
XOMA Ltd.

Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                                                                     May 4, 2005

Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C.  20549

Attention:  Michael Reedich
            Division of Corporation Finance

Re:  XOMA Ltd.
     Registration Statement on Form S-3
     File No. 333-123438
     Filed March 18, 2005, as amended April 28, 2005

Ladies and Gentlemen:

     Pursuant to Rule 461 under the Securities Act of 1933, the undersigned,
being the issuer of securities to which the referenced Registration Statement
relates, respectfully requests that the effectiveness of said Registration
Statement be accelerated so that it will become effective at 10:00 A.M. on May
6, 2005 or as soon thereafter as practicable.

     The disclosure in the filing is the responsibility of the Company. The
Company acknowledges that should the Commission or the staff, acting pursuant to
delegated authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing. The Company
further acknowledges that the action of the Commission or the staff, acting
pursuant to delegated authority, in declaring the filing effective, does not
relieve the Company from its full responsibility for the adequacy and accuracy
of the disclosures in the filing.

     The Company represents to the Commission that it will not assert this
action as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

<PAGE>

                                       -2-

                               Very truly yours,

                               XOMA Ltd.

                               By:  /s/ Christopher J. Margolin
                                    ----------------------------------
                                    Christopher J. Margolin
                                    Vice President, General
                                    Counsel and Secretary

</TEXT>
</DOCUMENT>