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CORRESP
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[REGENERON LETTERHEAD]

      August 19, 2009

BY EDGAR

Mr. Jeffrey Riedler
Assistant Director

Securities and Exchange
Commission
Division of Corporation Finance
100 F Street, NE

Washington, D.C. 20549

                  RE:

      Regeneron Pharmaceuticals, Inc.

Form 10-K for the fiscal year ended
      December 31, 2008
Filed February 26, 2009
Definitive Proxy Statement
      on Schedule 14A
Filed April 24, 2009
File No. 000-19034

Dear Mr. Riedler:

     This letter
sets forth the response of Regeneron Pharmaceuticals, Inc., a New York
corporation (the “Company”), to the additional comments of the staff of the
Securities and Exchange Commission (the “Staff”) set forth in the Staff’s letter
of August 10, 2009 (the “Comment Letter”) to Leonard S. Schleifer, M.D., Ph.D.,
President and Chief Executive Officer of the Company, regarding the
above-referenced definitive proxy statement on Schedule 14A (the “2009 Annual
Meeting Proxy Statement”). For the convenience of the Staff, this letter
restates in bold the comment in the Comment Letter, and immediately thereafter
sets forth the Company's response.

Mr. Jeffrey Riedler
Assistant Director

Securities and Exchange Commission
August
19, 2009
Page 2

Performance Based Vesting Stock
Options, page 25

    1.

      We note your response to comment
      5. Please provide proposed disclosure that you intend to provide in your
      proxy statement for the year 2009 which expands upon your description of
      the “point scale system” for the vesting of your performance based vesting
      stock options. Please include the following in your proposed disclosure:

  Discussion of the specific number of
  points or range of points awarded based on achievement of each of the
  development milestones you identify;

  Discussion of how the number of
  points earned corresponds to the amount of stock options that vest;

  Discussion of the minimum number of
  points that must be earned during the Performance Period for any of the
  performance based vesting options to vest; and,

  To the extent applicable, discussion
  of whether the Compensation Committee can exercise its discretion with regard
  to any of the bullets identified above.

     Please see
Exhibit A attached hereto. In compliance with the Staff’s comment, Exhibit A
sets forth proposed disclosure expanding upon the Company’s description in the
2009 Annual Meeting Proxy Statement of the “point scale system” for the vesting
of the Company’s performance based vesting stock options. Subject to appropriate
factual updating, the Company intends to include in its 2010 Annual Meeting
Proxy Statement disclosure in substantially the form set forth on Exhibit A. For
the convenience of the Staff, the text of Exhibit A has been marked to show
changes to the analogous paragraphs under the caption “Performance Based Vesting
Stock Options” in the 2009 Annual Meeting Proxy Statement. The proposed
disclosure set forth on Exhibit A includes the information requested in each of
the bullet points in the Staff’s comment. In this regard, the Company notes that
the last bullet point is addressed in and subsumed by the first sentence of the
last paragraph of the text of Exhibit A.

* * *

     As requested by the Staff, the
Company acknowledges that:

           (i) The Company is responsible for the adequacy and accuracy of the
      disclosure in the filings;

           (ii) Staff comments or changes to disclosure in response to Staff
      comments do not foreclose the Commission from taking any action with
      respect to the filings; and

           (iii) The Company may not assert Staff comments as a defense in any
      proceeding initiated by the Commission or any person under the federal
      securities laws of the United States.

* * *

Mr. Jeffrey Riedler
Assistant Director

Securities and Exchange Commission
August
19, 2009
Page 3

     If you have
any questions regarding the foregoing, please contact me at (914) 345-7498.

      Very truly yours,
REGENERON PHARMACEUTICALS, INC.

      /s/ Stuart A. Kolinski

      Stuart A. Kolinski
Senior Vice President, General Counsel
and Secretary

    cc:

      Securities and Exchange
      Commission
Bryan Pitko

      Skadden, Arps, Slate, Meagher & Flom LLP
Kent A. Coit, Esq.
Timothy F. Nelson,
    Esq.

Mr. Jeffrey Riedler
Assistant Director

Securities and Exchange Commission
August
19, 2009
Page 4

EXHIBIT A

Performance Based Vesting Stock
Options: These non-qualified stock options
will be eligible to vest on December 31 three years following the date of grant, 2011.
The number of stock options that will vest on that date will be determined based
on a point scale system, where points are earned upon the achievement of product
candidate development milestones between grant date and the vesting dateDecember 31, 2011 (the
Performance Measurement Period). The development milestones and the points
earned for achieving the development milestones are described below:

  filing of the first Investigational New
  Drug Application for a new product candidate (2 points each);

  data from a successful proof of concept
  study testing one of our product candidates (2 or 4 points each);

  filing of a Biologics License
  Application for one of our product candidates (5 or 7 points each); and

  approval of a Biologics License
  Application for one of our product candidates (20 or 28 points each).

     Later stage
development milestones earn incrementally more points than the earlier stage
development milestones. For the last three milestones described above, the
greater number of points more points areis earned for novel drug candidates and diseases and
the lesser number of points is earned than for follow-on product candidates with
potential competitive advantages over existing drugs that are approved for the
treatment of a disease.

     The number
of stock options from the award that will vest on the applicable December 31
vesting date will be calculated by multiplying the total number of stock options
subject to the award by a fraction, the numerator of which is the total number
of points earned during the Performance Measurement Period and the denominator
of which is 38, provided that no more than one hundred percent of the stock
option award can vest. If at least twelve a certain minimum number of points are not earned during the
Performance Measurement Period, or the applicable Named Officer ceases to be
employed by the company before the end of the Performance Measurement Period
(other than for reasons related to a change of control as discussed under the
heading Post-Employment Compensation on page 34), then none of the performance
based vesting stock options granted under the award will vest. Moreover, if we
do not file a Biologics License Application for at least one product candidate
during the Performance Measurement Period, then the maximum number of
performance based vesting stock options that can vest on the vesting dateDecember 31, 2011 is
capped at two-thirds of the total award, unless otherwise determined by the
Compensation Committee.

Mr. Jeffrey Riedler
Assistant Director

Securities and Exchange Commission
August
19, 2009
Page 5

     The
Compensation Committee retains the discretionright to accelerate the vesting of the
performance based stock options, either in whole or in part. Vesting of these
stock options may accelerate following a change of control as described under
the heading Post-Employment Compensation on page 34. As with the time based
vesting stock options, the performance based vesting stock options have a
ten-year term.