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SEC Company Response from XOMA Royalty Corp (CIK 0000791908) (XOMA) — Jun 3, 2011

XOMA Royalty Corp (CIK 0000791908)
Date: June 3, 2011 · CIK: 0000791908 · Accession: 0000950162-11-000131

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File numbers found in text: 333-172197

Date
June 3, 2011
Author
Christopher J. Margolin
Form
CORRESP
Company
XOMA Royalty Corp (CIK 0000791908)

Letter

corresp.htm

June 3, 2011

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention:

Johnny Gharib

Division of Corporation Finance

Re:

XOMA Ltd.

Registration Statement on Form S-3

File No. 333-172197

Filed February 11, 2011

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 the Registration Statement be accelerated so that it will become effective at 12:00 P.M. on June 6, 2011 or as soon thereafter as practicable.

The disclosure in the filing is the responsibility of XOMA Ltd. (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 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 disclosure in the filing; and

·

the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
XOMA Ltd.

Show Raw Text
CORRESP
1
filename1.htm

    corresp.htm

June 3, 2011

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention:

Johnny Gharib

Division of Corporation Finance

Re:

XOMA Ltd.

Registration Statement on Form S-3

File No. 333-172197

Filed February 11, 2011

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 the Registration Statement be accelerated so that it will become effective at 12:00 P.M. on June 6, 2011 or as soon thereafter as practicable.

The disclosure in the filing is the responsibility of XOMA Ltd. (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 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 disclosure in the filing; and

·

the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,

XOMA Ltd.

By:  /s/ Christopher J. Margolin

       Christopher J. Margolin

       Vice President, General

        Counsel and Secretary