SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

November 30, 2005

Mr. James M. Frates
Chief Financial Officer
Alkermes, Inc.
88 Sidney Street
Cambridge, MA  02139-4136

Re:	Alkermes, Inc.
	Form 10-K for the Fiscal Year Ended March 31, 2005
	Filed June 14, 2005
	File No. 001-14131

Dear Mr. Frates:

      We have reviewed your October 21, 2005 response to our
September 22, 2005 comment letter and have the following comments.
In our comments, we have asked you to provide us with information
so
we may better understand your disclosure.  After reviewing this
information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Consolidated Financial Statements, page F-1

Consolidated Statements of Operations and Comprehensive Loss, page
F-
3

1. Regarding your response to prior comment two, please further
clarify why it is sufficient to separately disclose your
manufacturing and royalty revenues only in MD&A, as Rule 5-
03(b)(1)
of Regulation S-X does distinguish between "net sales of tangible
products" and "other revenues".  In so doing, please address how
royalty revenues represent "net sales of tangible products", as
opposed to "other revenues", especially as your response indicates
that (a) manufacturing revenue is recognized upon shipment while
royalty revenues are recognized when the product is sold by your
customer and (b) there are no costs associated with royalty
revenues.
In addition, please tell us how your statements of operations
illustrate the relationship between "net sales of tangible
products"
and the "cost of tangible goods sold", as apparently contemplated
by
Rule 5-03(b)(1) and (2).

Notes to Consolidated Financial Statements, page F-6

9.  Convertible Preferred Stock, page F-18

2. We have the following comments about your response to our prior
comment five:

a. Please propose revisions to your balance sheets to clarify that
the convertible preferred stock is mezzanine equity, as it could
now
appear to be a liability.

b. Please tell us the "elements that were considered for
allocation
of proceeds" and how they were either "scoped out of separate
recognition" or "have no value".

c. As the fourth paragraph under "Measurement" in EITF D-98
appears
to contemplate that adjustments to the carrying amount could
result
in decreases to the carrying amount and increases in income
applicable to common stockholders in calculating EPS, please tell
us
what language in EITF D-98 supports your assertions that:

i. the "redemption amount" should be the greater of the initial
carrying amount or the fair value of consideration that you would
transfer upon redemption;

ii. "the spirit of EITF D-98 appears to require" that the carrying
amount "equal not just the fair value of assets that must be
transferred, but the fair value of future economic benefits that
would be forgone upon redemption";

iii. adjusting the stock "below its initial carrying amount ...
would
imply that the holders ... would make an uneconomic decision";
and,

iv. it is not appropriate to increase EPS on "the assumption that
investors will make an uneconomic decision to redeem the preferred
stock ..., unless and until such redemption occurred."

In addition, please explain why you appear to believe that the
excess
of the initial carrying amount over  fair value should not have
been
included in equity.  Finally, please tell us why you appear to
believe that EPS should not have been increased when the fair
value
was less than the initial carrying amount.

*    *    *    *

       Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provide the
requested information.  Detailed letters greatly facilitate our
review.  Please file your letter on EDGAR under the form type
label
CORRESP.

      You may contact Tabatha Akins, Staff Accountant, at (202)
551-
3658, or Oscar M. Young, Jr., Senior Accountant, at (202) 551-
3622,
if you have questions regarding the comments.  In this regard, do
not
hesitate to contact me, at (202) 551-3679.

Sincerely,

Jim B. Rosenberg
Senior Assistant Chief Accountant
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Mr. James M. Frates
Alkermes, Inc.
November 30, 2005
Page 3

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