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SEC Company Response from BIOCRYST PHARMACEUTICALS INC (BCRX) (CIK 0000882796) (BCRX) — Dec 15, 2006

BIOCRYST PHARMACEUTICALS INC (BCRX) (CIK 0000882796)
Date: Dec. 15, 2006 · CIK: 0000882796 · Accession: 0001035704-06-000826

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File numbers found in text: 000-23186

Referenced dates: November 15, 2005

Date
December 15, 2006
Author
/s/ Michael A. Darwin
Form
CORRESP
Company
BIOCRYST PHARMACEUTICALS INC (BCRX) (CIK 0000882796)

Letter

Via EDGAR and Overnight Courier Division of Corporation Finance BioCryst Pharmaceuticals, Inc. Form 10-K for the Fiscal Year Ended December 31, 2005 Filed March 9, 2006 File No. 000-23186

Dear Mr. Rosenberg:

This letter includes the acknowledgement requested by the Staff of the Securities and Exchange Commission in its letter dated November 15, 2005 to Charles E. Bugg, Ph.D. with respect to the above-referenced Annual Report on Form 10-K.

In connection with responding to the Staff’s comments, and as requested in the Comment Letter, the Company hereby acknowledges 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 initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
/s/ Michael A. Darwin

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CORRESP
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corresp

BIOCRYST PHARMACEUTICALS, INC.

2190 Parkway Lake Drive

Birmingham, AL 35244

December 15, 2006

Via EDGAR and Overnight Courier

Mr. Jim B. Rosenberg

Senior Assistant Chief Accountant

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D. C. 20549-6010

    Re:

    BioCryst Pharmaceuticals, Inc.

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

    Filed March 9, 2006

    File No. 000-23186

Dear Mr. Rosenberg:

     This letter includes the acknowledgement requested by the Staff of the Securities and Exchange
Commission in its letter dated November 15, 2005 to Charles E. Bugg, Ph.D. with respect to the
above-referenced Annual Report on Form 10-K.

     In connection with responding to the Staff’s comments, and as requested in the Comment Letter,
the Company hereby acknowledges 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 initiated
by the Commission or any person under the federal securities laws of the United States.

    Very truly yours,

    /s/ Michael A. Darwin

    Michael A. Darwin

    cc:

    Kei Ino

    Jim Atkinson

    Charles E. Bugg, Ph.D.

    Richard R. Plumridge, Esq.