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 May 16, 2025

Christopher Prentiss
Chief Financial Officer
MannKind Corporation
1 Casper Street
Danbury, Connecticut 06810

 Re: MannKind Corporation
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Filed February 26, 2025
 File No. 000-50865
Dear Christopher Prentiss:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 50

1. We note that sales of Tyvasco DPI under your Commercial Supply Agreement
(CSA)
 with United Therapeutics (UT) account for the majority of your
Collaboration and
 services revenue, which increased 90% from $53 million in 2023 to $100.9
million in
 2024. Based on your disclosure on page 94 and Section 3.01 of the CSA
included as
 an Exhibit to your filing, it appears that such sales are made to UT on
a cost plus
 margin basis. Given that the increase in your Cost of collaboration
revenue in 2024
 was only 41% compared to the prior year, it would appear that you
achieved higher
 margins on sales of Tyvasco DPI during 2024 than in 2023. However, your
disclosure
 on page 50 attributes the increase in revenue solely to higher patient
demand. Please
 clarify for us the factors underlying the increase in Collaboration and
services revenue
 and revise your disclosure in future filings accordingly.
 May 16, 2025
Page 2

Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Revenue Recognition - Collaboration and Services, page 79

2. You disclose that revenue under your CSA with UT is recognized for the
supply of
 product at a point in time, once control has transferred to UT. In your
auditors' Critical
 Audit Matter discussion, they disclose that revenue is recognized based
on the
 measure of progress as the performance obligation is satisfied and that
forecasted
 revenue over the contract term is utilized in determining the measure of
 progress. Please revise your accounting policy disclosure in future
filings to disclose
 the method used to measure revenue under your CSA as well as the
significant
 judgments used in determining your measure of progress. Please also
disclose how
 any changes in transaction price are recognized.

3. Pulmatrix Transaction, page 85

3. Please provide a detailed analysis supporting your accounting treatment
for the
 Pulmatrix Transaction as a business combination under ASC 805-10. Please
also
 provide us with copies of the Bill of Sale and Assignment Agreement,
Cross License
 Agreement and Master Services Agreement and explain your consideration
of filing
 these agreements as Exhibits to your filing. Finally, tell us your
consideration of
 providing disclosure in your future filings describing any material
rights or
 obligations under the contracts.

 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Frank Wyman at 202-551-3660 or Angela Connell at
202-551-3426
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
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