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SEC Company Response from VERTEX PHARMACEUTICALS (VRTX) — May 2, 2006

VERTEX PHARMACEUTICALS INC / MA (VRTX) (CIK 0000875320)
Date: May 2, 2006 · CIK: 0000875320 · Accession: 0001104659-06-030208

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File numbers found in text: 000-19319

Referenced dates: April 27, 2006

Date
May 2, 2006
Author
/s/ Kenneth S. Boger
Form
CORRESP
Company
VERTEX PHARMACEUTICALS INC / MA (VRTX) (CIK 0000875320)

Letter

Vertex Pharmaceuticals Incorporated

130 Waverly Street • Cambridge, MA 02139-4242

Tel: 617.444.6100 • Fax: 617.444.6680

www.vrtx.com

May 2, 2006

Submitted via EDGAR

Securities and Exchange Commission

450 Fifth Street, N.W.

Mail Stop 3-9

Washington, DC 20549

Attn:

Jim B. Rosenberg, Senior Assistant Chief Accountant

Oscar Young, Senior Accountant

James Peklenk, Staff Accountant

Division of Corporation Finance

Re:

Vertex Pharmaceuticals Incorporated

Form 10-K for the Fiscal Year Ended December 31, 2005

File No. 000-19319

Addendum to Response Letter dated April 27, 2006

Ladies and Gentlemen:

Reference is made to the letter, dated April 27, 2006 (the “Response Letter”), submitted to the Securities and Exchange Commission (the “Commission”) by Vertex Pharmaceuticals Incorporated (the “Company”) in response to comments received from the staff of the Securities and Exchange Commission in the form of a letter, dated April 14, 2006.

In connection with the Company’s submission of the Response Letter, the Company hereby acknowledges and confirms:

• the Company is responsible for the adequacy and accuracy of the disclosure in the filings;

• staff comments or changes to disclosure in 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 imitated by the Commission or any person under federal securities laws of the United States.

Please feel free to contact me in the event that you have any questions with respect to this matter.

Very truly yours,
/s/ Kenneth S. Boger

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CORRESP
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  Vertex Pharmaceuticals Incorporated

  130 Waverly Street • Cambridge, MA
  02139-4242

  Tel: 617.444.6100 • Fax: 617.444.6680

  www.vrtx.com

May 2, 2006

Submitted via
EDGAR

Securities and Exchange Commission

450 Fifth Street, N.W.

Mail Stop 3-9

Washington, DC 20549

  Attn:

  Jim B. Rosenberg, Senior Assistant Chief Accountant

  Oscar Young, Senior Accountant

  James Peklenk, Staff Accountant

  Division of Corporation Finance

  Re:

  Vertex Pharmaceuticals Incorporated

  Form 10-K for the Fiscal Year Ended December 31, 2005

  File No. 000-19319

  Addendum to Response Letter dated April 27, 2006

Ladies and Gentlemen:

Reference is made to the letter, dated April 27,
2006 (the “Response Letter”), submitted to the Securities and Exchange
Commission (the “Commission”) by Vertex Pharmaceuticals Incorporated
(the “Company”) in response to comments received from the staff of the
Securities and Exchange Commission in the form of a letter, dated April 14,
2006.

In connection with the Company’s submission of the Response Letter, the
Company hereby acknowledges and confirms:

•                  the
Company is responsible for the adequacy and accuracy of the disclosure in the
filings;

•                  staff
comments or changes to disclosure in 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
imitated by the Commission or any person under federal securities laws of the
United States.

Please feel free to contact me in the event that you have any questions
with respect to this matter.

  Very truly yours,

  /s/ Kenneth S. Boger

  Kenneth S. Boger

  Senior Vice President and General Counsel