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SEC Company Response from XOMA Royalty Corp (CIK 0000791908) (XOMA) — Nov 1, 2010

XOMA Royalty Corp (CIK 0000791908)
Date: Nov. 1, 2010 · CIK: 0000791908 · Accession: 0000950162-10-000342

Regulatory Compliance Financial Reporting Internal Controls

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File numbers found in text: 000-14710

Referenced dates: October 20, 2010

Date
November 1, 2010
Author
/s/ Kimberly C. Petillo
Form
CORRESP
Company
XOMA Royalty Corp (CIK 0000791908)

Letter

Form 10-K for the Fiscal Year Ended December 31, 2009 Filed March 11, 2010 Form 10-K/A filed April 30, 2010 File No. 000-14710

Re:

Dear Mr. Riedler:

On behalf of XOMA Ltd. (the “Company”) and as discussed by telephone on October 29, 2010 with Laura Crotty, we have requested an extension of time to reply to your letter dated October 20, 2010 to Mr. Steven B. Engle of the Company, regarding the above-referenced report, until November 17, 2010. Per my telephone conversation on October 29, 2010 with Ms. Crotty, our request for an extension until November 17, 2010 was granted.

The Company appreciates the Staff’s consideration. The Company continues to diligently prepare a response.

Please direct any questions or concerns regarding this request to the undersigned at the number indicated above. Thank you for your attention.

Sincerely,
/s/ Kimberly C. Petillo

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CORRESP
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filename1.htm

    correspondence.htm

[Cahill Gordon & Reindel llp Letterhead]

(212) 701-3265

November 1, 2010

Re:

XOMA Ltd.

Form 10-K for the Fiscal Year Ended December 31, 2009

Filed March 11, 2010

Form 10-K/A filed April 30, 2010

File No. 000-14710

Dear Mr. Riedler:

On behalf of XOMA Ltd. (the “Company”) and as discussed by telephone on October 29, 2010 with Laura Crotty, we have requested an extension of time to reply to your letter dated October 20, 2010 to Mr. Steven B. Engle of the Company, regarding the above-referenced report, until November 17, 2010.  Per my telephone conversation on October 29, 2010 with Ms. Crotty, our request for an extension until November 17, 2010 was granted.

The Company appreciates the Staff’s consideration.  The Company continues to diligently prepare a response.

Please direct any questions or concerns regarding this request to the undersigned at the number indicated above.  Thank you for your attention.

                Sincerely,

                /s/ Kimberly C. Petillo

                Kimberly C. Petillo

Jeffrey P. Riedler

Assistant Director

Division of Corporation Finance

United States Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C.  20549

VIA ELECTRONIC TRANSMISSION/BY HAND

cc:

Laura Crotty

Christopher J. Margolin

Geoffrey E. Liebmann