SecProbe.io

July 30, 2010
 Jeffrey H. Cooper Senior Vice President, 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, 2009
 Filed February 26, 2010
  Form 8-K Filed March 24, 2010
 Proxy Statement on Schedule 14A
 Filed March 26, 2010
  File Number: 000-26727

Dear Mr. Cooper:
 We have reviewed your filings and have th e following comments.  In our comments, we
ask you to provide us with information so  we may better underst and your disclosure.
 Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response.  Where a comment requests you to revise disclosu re, the information you provide s hould 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 be lieve a comment applies to your facts and
circumstances, please tell us why in your res ponse.  Please furnish us a letter on EDGAR under
the form type label CORRESP that ke ys your responses to our comments.
 After reviewing the information provided, we may raise additional comments and/or
request that you amend your filings.              Form 10-K for the fiscal year ended December 31, 2009

 Item 1. Business, page 1

1. We note your discussion of various license and collaboration agreements throughout this
section of the filing.   Please revise your disc losure to include a summary of the duration and
termination provisions of each material agreement.

Jeffrey H. Cooper
BioMarin Pharmaceutical Inc.
July 30, 2010
Page 2

Commercial Products, page 3
2. We note the discussion of your exclusive license agreement with Asubio Pharma Co., Ltd. on
page 4 of the filing.  Please revise your disc losure to quantify the to tal potential milestone
payments due under the agreement and to provi de a more narrow range of royalties paid
within ten percentage points.

Patents and Proprietary Rights, page 9
 3. Please revise your disclosure on page 9 to in clude the expiration year of each of your
material patents.
 Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations
4. You disclose, on page 4, that the granted orpha n drug status and the re lated seven years of
market exclusivity in the U.S. for Aldurazyme expires in 2010.  In a ddition, you disclose that
sales of Aldurazyme make up over 22% of your total net sales for the year ended December
31, 2009.  Please revise your disclosure to discus s the expected impact that the expiration of
the exclusive right in the U.S. will have on your future results of operations and liquidity.

Consolidated Financial Statements
 Notes to Consolidated Financial Statements

 Note 11.  Convertible Debt, page F-30

5. You disclose that the conversion price is subjec t to adjustment in certain circumstances.
Please disclose the circumstances that would re sult in an adjustment to the conversion price
and tell us how you determined that the conve rsion feature was not an embedded derivative
under ASC 815-15-25 which would require fa ir value accounting under ASC 470-20-25.

Note 14.  Income Taxes, page F-35
6. Please revise your disclosure to clarify what is included in the permanent items line item of
the tax reconciliation on page F-36 and explain the major changes in this line item for the
periods presented.

 Form 8-K filed March 24, 2010

7. In your response to several of the statements  and assertions made by Mr. Klein in his
Resignation Letter and the Company’s posit ion on the circumstances surrounding Mr.
Klein’s resignation you disclose a disagreem ent regarding how to conduct an ongoing

Jeffrey H. Cooper
BioMarin Pharmaceutical Inc.
July 30, 2010
Page 3

investigation regarding a serious matter.  Please tell us the nature of the matter being
investigated by the Audit Committee a nd status of this investigation.

Definitive Proxy Statement on Schedule 14A

Compensation Discussion and Analysis
 Cash Bonus, page 34

8. We note the following statement beginning on pa ge 34 of your defini tive proxy statement:
“We have not disclosed the spec ific corporate goals as they are based on various strategic
elements, each of which is confidential a nd the Compensation Committee has determined
that disclosure of the goals can result in competitive harm to us.”  Please provide us with an analysis supporting your determination that disc losure of the specific corporate goals would
result in competitive harm to the company.  To avoid the disclosure of the sensitive information in the analysis when our comment  letters are released publicly, you may submit
a confidential treatment reque st pursuant to Rule 83.  Ot herwise, please provide draft
disclosure to be includ ed in your next annual filing whic h discloses the specific corporate
goals and the threshold, target and maximum leve ls of performance which must be achieved
to reach the payout levels described in the firs t full paragraph on page 36.  To the extent the
goals are quantifiable, your discus sion should also be quantified.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provi de a written 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 filings; 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.

Jeffrey H. Cooper
BioMarin Pharmaceutical Inc.
July 30, 2010
Page 4

 You may contact Dana Hartz,  Staff Accountant, at (202) 551-3648 or Don Abbott, Senior
Staff Accountant, at (202) 551-3608 if you have a ny questions regarding the processing of your
response as well as any questions regarding co mments on the financial statements and related
matters. You may contact Laura Cr otty, Staff Attorne y, at (202) 551-3563 with questions on any
of the other comments.  In this regard, do not hesitate to contact  me, at (202) 551-3679.

Sincerely,

Jim B. Rosenberg
Senior Assistant Chief Accountant