SecProbe.io

Mail Stop 4720

June 23, 2016

VIA E -mail
Mr. Daniel Spiegelman
Chief Financial Officer
Biomarin Pharmaceutical Inc.
770 Lindaro Street
San Rafael, CA  94901

Re: Biomarin Pharmaceuticals Inc.
 Form 10-K for Fis cal Year Ended December 31, 2015
Filed  February 29 , 2016
File No. 0-26727

Dear Mr. Spiegelman :

We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment , we ask you to provide us with
information so we may better understand your disclosure.

Please respond to th e comment  within ten business days by providing the requested
information or advise us as soon as pos sible when you will respond.  If  you do not believe the
comment applies  to your facts and circumstances, please tell us why in your response.

After reviewing your response to the comment , we may have additional comments.

Notes to Consolidated Financi al Statements
(3) Summary of Significant Accounting Policies
Revenue Recognition
Net Product Revenues, page F -11

1. You state on page F-13 that due to the significant role you play in the operations of
Aldurazyme and Kuvan , you elected not to classify the Aldurazyme and Kuvan royalties
earned as royalty, license and other revenues and instead include them as a component of
net product revenues.  Please provide us a detailed analysis with reference to the
authoritative liter ature to which you rely as to why classification of royalties  earned as
net product revenues is appropriate , excluding the portion attribu ted to product transfer
revenue .

Mr. Daniel Spiegelman
Biomarin Pharmaceuticals Inc
June 23, 2016
Page 2

 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 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 adequacy of the disclosures they have made.

 In responding to our comment, 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;
 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.

You may contact  Senior Staff Accountant  Mary Mast at (202) 551 -3613 with any
questions .  In this regard, do not hesitate to contact me at (20 2) 551 -3679.

Sincerely,

 /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant
         Office of Healthcare and Insurance