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Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                   December 20, 2007   Mr. Jeffrey H. Cooper Chief Financial Officer BioMarin Pharmaceutical, Inc. 105 Digital Drive Novato, CA  94949
Re: BioMarin Pharmaceutical, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2006 Form 10-Q for the quarterly p eriod ended September 30, 2007
 File No. 000-26727

Dear Mr. Cooper:

We have reviewed your filing and have the following comments. We have limited
our review to your financial statements a nd related disclosures and do not intend to
expand our review to other portions of your document. In our comments, we ask you to
provide us with information to better unde rstand your disclosure.  Where a comment
requests you to revise disclosure, the info rmation you provide should show us what the
revised disclosure will look like and identify the annual or quarterly filing, as applicable,
in which you intend to first 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.
 Item 9A. Controls and Procedures, page 50

Evaluation of Disclosure Cont rols and Procedures, page 50
 1. You state that your CEO and CFO have c oncluded that your di sclosure controls
are “sufficiently effective.”  The use of terminology other than effective raises the
question if you are attempting to state that disclosure controls and procedures met

Mr. Jeffrey H. Cooper
BioMarin Pharmaceutical, Inc. December 20, 2007 Page 2
 some standard lower than effective. Please  revise your disclosure.  Refer to Item
307 of Regulation S-K.
 Financial Statements – December 31, 2006

 (2) Summary of Significant Accounting Policies, page F-9

(s) Reclassifications, page F-17
 2. Please explain to us why you classified  cash outflows for property, plant and
equipment within cash flows from operati ons instead of inve sting activities.
 Form 10-Q – September 30, 2007

 (2) Summary of Significant Accounting Policies, page 6

(c) Revenue Recognition, page 7
Royalty and license revenues, page 9
 3. Please explain to us why you believe that  the milestone payment received related
to the “one-year anniversary” of FDA a pproval recorded in the current period
represented a substantive mile stone, as its receipt is base d solely on the passage of
time from FDA approval.

***************************

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that  keys your response to our
comments and provide the requested information.  Detailed letters gr eatly facilitate our
review.  Please furnish the 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

Mr. Jeffrey H. Cooper
BioMarin Pharmaceutical, Inc. December 20, 2007 Page 3
 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.
 You may contact Sasha Pa rikh, Staff Accountant, at  (202) 551-3627 or Jim
Atkinson, Accounting Branch Chief, at (202)  551-3674 if you have questions regarding
the comments.  In this regard, do not he sitate to contact me at (202) 551-3679.
  Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant