SecProbe.io

April 17 , 2014

Via E -mail
Robert E. Landry
Senior Vice President, Finance and Chief Financial Officer
Regeneron Pharmaceuticals, Inc.
777 Old Saw Mill River Road
Tarrytown, New York 10591

Re: Regeneron Pharmaceuticals, Inc.
   Form 10-K for the Fi scal Year Ended December 31, 2013
   Filed February 13, 2014
   File No. 000-19034

Dear M r. Landry :

We have reviewed your filing and have the following comment s.  In our comment s, we
ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within 10 business days by  providing us the requested
information or  by advising us when you will provide the requested response.   If you  do not
believe a comment  applies to your facts and circumstances, please tell us why in your response.
Please furnish us a letter on EDGAR under the form type label CORRESP that key s your
response to our comment s.

After reviewing the information provide d, we may raise additional comments  and/or
request that you amend your filing .

Part III, page 83

1. We have not yet reviewed the Part III information that is included in your Form 10 -K.
We may have further comments after reviewing that information and we wi ll not be able
to clear our review of your filing until we have the opportunity to resolve any resulting
comments.

Notes to Consolidated Financial Statements
13. Commitments and Contingencies
b. Research Collaboration and Licensing Agreements, page F -29

2. Regarding your Genentech agreement, please tell us how you concluded that recognizing
royalty  expense using a blended mid -single digit royalty rate that reflects both the $60
million payment and the royalties payable on cumulative sales is appropriate, as opposed
to expensing the $60 million  upon cumulative U.S. sales of EYLEA reaching $400

Robert E. Landry
Regeneron Pharmaceuticals, Inc.
April 17 , 2014
Page 2

 million in 2012 and expensing  the royalties  for sales over $400 million at the contractual
rate when incurred . Please cite the authoritative literature used to support y our
conclusion.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be  certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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 comment s, please provide  a written state ment from the company
acknowledging that:
 the company is responsible for the adequacy and accuracy of the disclosure in the filing;
 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action  with respect to the filing; and
 the company may not assert staff comments as a defense in any proceeding initia ted by
the Commission or any person under the federal securities laws of the United States.

You may contact Scott Wuenschell, Staff Accountant,  at (202) 551 -3467 or Joel Parker,
Accounting Branch Chief, at (202) 551 -3651 if you have questions regarding the processing of
your response as well as any questions regarding comments on the financial statements and
related matters. You may contact Austi n Stephenson, Staff Attorney, at (202) 551 -3192 or Bryan
Pitko , Attorney Advisor at (202) 551 -3203  with questions on any of the other comments.  In this
regard, do not hesitate to contact me at (202) 551 -3679.

Sincerely,

 /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant