SecProbe.io

May 8, 201 3

Via E -mail
Mr. Daniel Spiegelman
Executive Vice President and
Chief Financial Officer
BioMarin Pharmaceutical Inc.
770 Lindaro Street
San Rafael, CA 94901

Re:  BioMarin Pharmaceutical Inc.
Form 10 -K for the Fiscal Year Ended December 3 1, 2012
Filed February 26 , 2013
Form 10 -Q for the Quarterly Period ended March 31, 2013
Filed April 29, 2013
  File No.  000-26727

Dear Mr. Spiegelman :

We have reviewed your filing s and have the following comment s.  In our comment s, we
ask you to provide us with information so we may better understand 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 circumstances, please tell us why in your response.
Please furnish us a letter  on EDGAR under the form type label CORRESP that key s your
response s to our comment s.

After reviewing the information you provide in response to th ese comment s, we may
have additional comments and/or request that you amend your filing s.

Form 10 -Q for the  Quarterly Period ended March 31, 2013
Notes to the Consolidated Financial Statements.
Note 10.  Inventory, page 11

1. Please provide us proposed revised disclosure to be included in future periodic reports
indicating revisions to your accounting policy rega rding capitalization of inventory costs
prior to regulatory approval that specifically states the point during the FDA approval
process that you determine a probable future benefit exists and the status of the FDA’s
consideration of the safety and efficacy  of the drug/system and evaluation of the
manufacturing process at that point.   Disclose how you apply the lower of cost or market
principle to your pre -launch inventory.

Mr. Daniel Spiegelman
BioMarin Pharmaceutical Inc.
May 8, 201 3
Page 2

 2. In addition, please provide us proposed revised disclosure to be included in future periodic
reports that discusses the overall FDA approval process; the description should meaningfully
relate to your accounting policy for pre -launch inventory.   For each product with significant
costs capitalized in inventory prior to regulatory approval,  discuss the following:

 The current status of the approval process, including any contingencies needed to be
resolved prior to obtaining FDA approval, the risks affecting the probability of
obtaining FDA approval, and the estimated timing of obtaining ap proval.
 The specific nature of any safety and efficacy, manufacturing, and marketing or
labeling issues outstanding and why you do not believe those issues affect its
probable future benefit conclusion.
 The remaining shelf life of each product, as of each  balance sheet date presented, and
why you believe you will be able to realize the inventory prior to the expiration of the
shelf life.
 The risks and uncertainties surrounding market acceptance of the product once
approved and how this will affect the real ization of the asset.

We urge all persons who are responsible for the accuracy and a dequacy of the disclosure
in the filing s to be certain that the filing s include the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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 a dequacy of the disclosures they have made.

In responding to our comment s, please provide a written statement from the company
acknowledging that:
 the company is responsible for the adequacy and accuracy of the disclosure in the
filing s;
 staff comments o r changes to disclosure in response to staff comments do not
foreclose the Commission from taking any  action with respect to th e filing s; 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.

You may c ontact Dana Hartz, Staff Accountant, at (202) 551 -3648 or Lisa Vanjoske ,
Assistant Chief Accountant , at (202) 551 -3614 if you have questions . In this regard, do not
hesitate to contact me a t (202) 551 -3679.

Sincerely,

 /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant