SecProbe.io

Via Facsimile and U.S. Mail
Mail Stop 6010
        February 27, 2008

Mr. Peter D. Meldrum
President and Chief Executive Officer
Myriad Genetics, Inc.
320 Wakara Way
Salt Lake City, UT  84108

Re: Myriad Genetics, Inc.
 Form 10-K for Fiscal Year Ended June 30, 2007
 File No. 0-26642

Dear Mr. Meldrum:

We have reviewed your filing and have the following comments.  In our
comments, we ask you to provide us with  information to better understand your
disclosure.  Where a comment requests you to  revise disclosure, the information you
provide should show us what the revised disc losure will look like and identify the annual
or quarterly filing, as appli cable, in which you intend to fi rst include it.  If you do not
believe that revised disclosure  is necessary, explain the reason in your response.  After
reviewing the information provided, we may raise additional comments and/or request
that you amend your filing.

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

Form 10-K for the fiscal year ended June 30, 2007

Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

Overview, page 31
 1. You do not appear to separately quan tify costs incurred for your five product
candidates or provide sufficient inform ation that would allow investors to
determine the reasonably likely timi ng for your product commercialization and
related revenue generation. Please revise your  disclosure to provide the following
information for each of these research and development projects. Refer to the

Mr. Peter D. Meldrum
Myriad Genetics, Inc.
February 27, 2008
Page 2
Division of Corporation Finance “Curre nt Issues and Ru lemaking Projects
Quarterly Update” under section VIII – I ndustry Specific Issues – Accounting and
Disclosure by Companies Engaged in Research and Development Activities.  You can find it at the following website address: http://www.sec.gov/divisions/c orpfin/cfcrq032001.htm#secviii
.

a. The costs incurred during each period presented and to date on the project;
b. The nature, timing and estimated costs of the efforts necessary to complete the project;
c. The anticipated completion date for the project;
d. The risks and uncertainties associated with completing development on schedule, and the consequences to oper ations, financial position and liquidity
if the project is not completed timely; and
e. The period in which material net cash in flows from the project are expected
to commence.

Regarding a. if you do not maintain a ny research and development costs by
project, disclose why management does not maintain and evaluate research and development costs by project.  Provide othe r quantitative or qualitative disclosure
that indicates the amount of the company’ s resources being used on the project.

Regarding b. and c. disclose the amount or range of estimated costs and timing to
complete the phase in process and each future phase. To the extent that information is not estimable, disclose those facts and circumstances indicating the uncertainties that preclude you fr om making a reasonable estimate.
 Critical Accounting Policies, page 31

 2. You disclose that your estimate for the allowance for doubtful accounts requires difficult, subjective or complex judgment s.  In Business on page 11 you indicate
that sales of your therapeutic and molecular diagnostic products depend
significantly on the availability of thir d-party reimbursement.  It is unclear
whether your allowance for doubtful accounts relates solely to bad debt expense
or whether it includes contractual allo wances for concessions to third-party
payors.  Please address the following comments:

a. Please revise your revenue recogniti on policy disclosure and critical
accounting policy disclosure to clea rly indicate how you account for
contractual allowances due to third-party payors.  In this regard, please
clarify whether your receivables and revenues are presented net of third-
party allowances.
b. Please disclose whether your accrued liabilities include estimates for
contractual allowances, rebates and/ or discounts.  In addition, please
revise your financial statement disclo sure to provide each accrual greater

Mr. Peter D. Meldrum
Myriad Genetics, Inc.
February 27, 2008
Page 3
than 5% of current liabilities as required by Item 5-02.20 of Regulation S-
X.
c. Please revise your critical accounting policies disclosure to provide the
effect that a reasonably likely change could have, as of the latest balance
sheet provided, on your estimate of the allowance for doubtful accounts.  In addition, for each period presented pl ease revise to disclose the dollar
amount effect that the revision to your prior-period estimate of the
allowance had on your results of operations.  Please see FR-72.
 Results of Operations, page 32

 3. Please revise your disclosure to separately  discuss the impact of price and volume
changes on your reported revenues as re quired by Item 303(a)(3)(iii) of
Regulation S-K.
 Contractual Obligations, page 36

 4. Please revise your contractual obligations table to present in the table or in a
footnote thereto the aggregate total potent ial milestone obliga tions you identify in
Business on page 8, as required by Item 303(a)(5) of Regulation S-K.  In addition, please revise your financial statement f ootnote disclosures to include the amount
of your commitments under these arrange ments and the events that trigger
payments of the milestones.
 Financial Statements

 Note 8:  Segment and Rela ted Information, page F-17

 5. Please revise your disclosure to provide the following information:

a. The amount of assets by segment and a reconciliation to your total assets
as required by paragraph 25 of SFAS 131.
b. The amount of your diagnostic revenues  by product or group of products
as required by paragraph 37 of SFAS 131.  In this regard, it appears that
you identify your individual diagnost ic products in Business on page 4.
 Note 10:  Investment in Prolexys  Pharmaceuticals, Inc., page F-19

 6. It appears that your invest ment in Prolexys meets the 20% significance levels
under Item 3-09 of Regulation S-X for at least fiscal 2005 and fiscal 2006.
However, it does not appear that you provide  the required financial statements of
Prolexys in either this Form 10-K or t hose of the preceding two fiscal years.
Please provide us your significance tests under Item 3-09 of Regulation S-X for
your equity investment in Prolexys for each of the last three fiscal years and

Mr. Peter D. Meldrum
Myriad Genetics, Inc.
February 27, 2008
Page 4
explain to us why you have not provided the audited or unaudited financial statements required under that rule.

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

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging 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.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 If you have any questions, please co ntact Mark Brunhofer , Senior Staff
Accountant, at (202) 551-3638.  In  this regard, do not hesita te to contact me, at (202)
551-3679.

Sincerely,

Jim B. Rosenberg Senior Assistant Chief
Accountant