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SEC Company Response from XOMA Royalty Corp (CIK 0000791908) (XOMA) — Mar 18, 2011

XOMA Royalty Corp (CIK 0000791908)
Date: March 18, 2011 · CIK: 0000791908 · Accession: 0000950162-11-000082

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File numbers found in text: 333-172197

Referenced dates: February 16, 2011

Date
March 18, 2011
Author
Geoffrey E. Liebmann
Form
CORRESP
Company
XOMA Royalty Corp (CIK 0000791908)

Letter

XOMA Ltd. Registration Statement on Form S-3 Filed February 11, 2011 File No. 333-172197

Re:

Dear Mr. Riedler:

This letter is submitted on behalf of XOMA Ltd. (the “Company”) in response to your comment letter dated February 16, 2011 relating to the Company’s Registration Statement on Form S-3 (File No. 333-172197), filed on February 11, 2011 (the “Registration Statement”), and in conjunction with the filing of Amendment No. 1 to the Registration Statement, filed on March 10, 2011 (the “Amendment”).

In response to your comment, as requested, the Company has revised the disclosure to specifically state that McNicoll, Lewis & Vlak LLC is an underwriter, which revisions are reflected on the cover page and in the “Plan of Distribution” section of the MLV sales agreement prospectus in the Amendment.

-2-

Your attention to this filing and this response is greatly appreciated. Any questions or further comments regarding this filing should be directed to the undersigned at the number indicated above.

Sincerely,
Geoffrey E. Liebmann

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CORRESP
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    corresp.htm

[Letterhead of Cahill Gordon & Reindel llp]

(212) 701-3313

March 18, 2011

Re:

XOMA Ltd.

Registration Statement on Form S-3

Filed February 11, 2011

File No. 333-172197

Dear Mr. Riedler:

This letter is submitted on behalf of XOMA Ltd. (the “Company”) in response to your comment letter dated February 16, 2011 relating to the Company’s Registration Statement on Form S-3 (File No. 333-172197), filed on February 11, 2011 (the “Registration Statement”), and in conjunction with the filing of Amendment No. 1 to the Registration Statement, filed on March 10, 2011 (the “Amendment”).

In response to your comment, as requested, the Company has revised the disclosure to specifically state that McNicoll, Lewis & Vlak LLC is an underwriter, which revisions are reflected on the cover page and in the “Plan of Distribution” section of the MLV sales agreement prospectus in the Amendment.

-2-

Your attention to this filing and this response is greatly appreciated.  Any questions or further comments regarding this filing should be directed to the undersigned at the number indicated above.

Sincerely,

Geoffrey E. Liebmann

Mr. Jeffrey Riedler

Assistant Director

Division of Corporation Finance

US Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

VIA ELECTRONIC SUBMISSION AND FACSIMILE

cc:

Johnny Gharib, Division of Corporation Finance

Christopher J. Margolin, XOMA Ltd.