SecProbe.io

March 23, 2012
 Via E-mail

Mr. Jeffrey H. Cooper Senior Vice President and 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, 2011
Filed February 22, 2012
  File No.  000-26727

Dear Mr. Cooper:
We have limited our review to only your fina ncial statements and related disclosures and
do not intend to expand our review to other porti ons of your document.  In our comments, we ask
you to provide us with information so we may better understa nd your disclosure.

Please respond to this letter within 10  business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not
believe a comment applies to your facts and circ umstances, please tell us why in your response.
Please furnish us a letter on EDGAR under the fo rm type label CORRESP that keys your
responses to our comments.

After reviewing the information you provide in response to these comments, we may
have additional comments and/or request that you amend your filing.  Management’s Discussion and Analysis

Provision for Income Taxes, page 57

1. You indicate here that the 2011 provision for income taxes relates to foreign and state
income taxes yet page F-41 shows the majority of 2011 income tax expense was federal.  Please provide us proposed disclosure to be  included in future periodic reports
reconciling these two disclosures or tell us why you believe no revision is necessary.
Also explain why a provision for current fe deral income tax is required when you are
utilizing net operating loss carryforwards.

Mr. Jeffrey H. Cooper
BioMarin Pharmaceutical Inc.  March 23, 2012 Page 2

 Financial Statements

(21) Revenue and Credit Concentrations, page F-39

2. Please provide us proposed disclosure to be included in future periodic reports that
discloses the amount of accounts receivable th at is past due by count ry related to Italy,
Spain, Portugal and Greece and the number of days past due. Disclose  the portion in each
of these countries that is due directly fr om the government or funded by the government.
Tell us the amount of allowance for doubtfu l accounts at December 31, 2011 related to
receivables in each of these countries and w hy you consider that amount to be adequate.
 (22) Income Taxes, page F-40

3. Please provide us proposed disclosure to be in cluded in future periodic reports explaining
why you are recognizing foreign current in come tax expense when you show losses
before income tax from non-U.S. sources for a ll three years.  Also disclose why the losses
from non-U.S. sources do not appear to be reported as foreign net operating loss
carryforwards. Tell us why the losses  increased greatly in 2010 and 2011.

4. You disclose “Based on projected U.S. taxa ble income and other key operating factors,
the Company concluded in 2010 that it is more likely than not that a significant portion of
the benefit of its deferred tax assets would be  realized. As a result, the amount of the
valuation allowance related to the deferred tax assets expected to be realized was
reversed, resulting in a net tax benefit in  2010 of $230.6 million, which was recorded as a
tax benefit in the Company's consolidated statement of operations in 2010.”  Please
provide us with a detailed analysis to suppor t your conclusion that no additional valuation
allowance was warranted. Your response s hould address both the positive and negative
evidence you considered in making this determination in accordance with ASC 740.

We urge all persons who are responsible for th e 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 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.

Mr. Jeffrey H. Cooper
BioMarin Pharmaceutical Inc.  March 23, 2012 Page 3

 You may contact Lisa Vanjoske , Assistant Chief Accountant,  at (202) 551-3614 or Joel
Parker, Accounting Branch Chief, at (202) 551-3651 if you have quest ions regarding these
comments.  In this regard, do not hesita te to contact me at (202) 551-3679.

Sincerely,
  /s/ Jim B. Rosenberg
Jim B. Rosenberg Senior Assistant Chief Accountant