SecProbe.io

November 16, 2010

Mr. Jon P. Stonehouse President and Chief Executive Officer Biocryst Pharmaceuticals, Inc. 2190 Parkway Lane Drive Birmingham, AL  35244
Re: Biocryst Pharmaceuticals, Inc.
Form 10-K for the year ended December 31, 2009 Filed March 9, 2010 Definitive Proxy Statement on Schedule 14A Filed April 6, 2010 File No. 000-23186
 Dear Mr. Stonehouse:
 We have reviewed your September 9, 2010 re sponse to our August 25, 2010 letter and
have the following comments.
Please respond to this letter within ten business days by providing us the requested
information or by advising us when you will provid e the requested response.  Please furnish us a
letter on EDGAR under the form type label CORRESP that keys your responses to our
comments.

After reviewing the information provided, we may have additional comments.

Schedule 14A

1. Please refer to your responses to comments 4, 5, and 6 in your respons e letter.  Pease note
that when we ask you to revise your disclosu re, we request that you amend your Form 10-K
for the Fiscal Year Ended December 31, 2009 to include the requested disclosure.  Accordingly, we will not be able to clear your filing of comments until you have filed an
amended Form 10-K with the requested disclosure.

Form 10-K for the year ended December 31, 2009

Compensation Discussion and Analysis
Annual Incentive Compensation, page 24

2. We note your responses to Comments 4 and 5 and reissue the comments in part.  Please
expand the proposed disclosure to be included in an amendment to your Form 10-K for the
fiscal year ended December 31, 2009 to disclose:

Mr. Jon P. Stonehouse Biocryst Pharmaceuticals, Inc. November 16, 2010 Page 2

• Specific examples of corporate and indivi dual objectives that would increase the
understanding of the corporat e and individual objectives , respectively, as you propose
to do in the future;
• The evaluation by the Compensation Committ ee of the level of achievement by the
company of corporate goals and by each named executive officer of the individual
performance objectives applicable to them.

Please note that it is not sufficient to disc lose only the amounts awarded under the AIP in
2009 and the achievement of corporate objectives, instead of describing the
Compensation Committee’s assessment of the le vel of achievement of each individual
performance objective.  To the extent that  you are concerned about the release of our
correspondence, you may request co nfidential treatment pursuant to Rule 83.  In order to
do this, please file on EDGAR your supplem ental response reque sting confidential
treatment under Rule 83, redac ting the information you request to remain confidential.
Please note that only those words, numbers and phrases for which confidentiality is necessary should be redacted.  Further,  an unredacted copy of your supplemental
response requesting Rule 83 treatment must  be mailed directly to the Staff.

Please note that in order to keep your pe rformance metrics conf idential pursuant to
Instruction 4 to Item 402(b) of Regulation S-K you must submit an  analysis supporting
your conclusion that you are li kely to suffer competitive harm if the information is
disclosed. We are generally onl y willing to grant confidential  treatment for performance
goals if you can demonstrate how the disclosure of these goals will allow your competitors to discover information about brea k even points, cost structures relating to
specific products or similarly sensitive info rmation. In these instances, you must submit a
detailed analysis, identifying the competitively harmful information and demonstrating how the information could be harmful to your company.

You may contact Rose Zukin, Staff Attorney  at (202) 551-3239 with questions on the
comments.  In this regard, do not hes itate to contact me, at (202) 551-3679.

Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant