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  [ABGENIX
  LETTERHEAD]

  June 8, 2005

  Securities and Exchange Commission

  Division of Corporate Finance

  450 Fifth Street, N.W.

  Washington, D.C. 20549

  Attention:

  Jim B. Rosenberg, Esq.

  Re:

  Abgenix, Inc.

  Form 10-K for fiscal year ended December 31,
  2004

  File No. 000-24207

Ladies and
Gentlemen:

Abgenix, Inc.
(the “Company”) hereby respectfully submits this letter in response to the
verbal comments provided by the Staff following the Company’s initial written
response dated April 19, 2005 to the Staff’s letter dated April 5,
2005, from Mr. Jim B. Rosenberg to Mr. H. Ward Wolff of the Company.

The Company’s current policy regarding the
classification of its joint development arrangements is disclosed in the notes
to the consolidated financial statements in its Annual Report on Form 10-K
for the year ended December 31, 2004.
Under these arrangements, the Company and its joint development partner
share the costs of developing and commercializing antibody therapeutic products
equally.  The policy states that in
periods where the joint development partner incurs more development costs than
the Company, the Company records expense for the services received.  In these circumstances, no revenue is
recorded by the Company.  Alternatively,
in periods where the Company incurs more costs under the arrangement than the
joint development partner, the Company records contract revenue for the
services rendered to the joint development partner to the extent that the
Company’s costs exceed the costs incurred by the joint development partner.

The Staff
requested the Company to reconsider its classification on the statement of
operations of the joint-development payments to or from its joint development
partners.  In response to the Staff’s request, the
Company has evaluated industry practice for the classification of joint
development activities by reviewing the filings of several registrants.  The Company observed that there is
significant diversity in practice on this issue and that several registrants
have applied an accounting policy that is consistent with the policy used by
the Company.  The Company has also
performed a review of the accounting literature related to revenue recognition
and did not identify any accounting literature that it

considered to be directly on point.  The Company believes that its historical
accounting policy is supportable for the reasons set forth in its letter dated April 19,
2005.

Notwithstanding
the above, the Company supports the Staff’s efforts to promote consistency in
the presentation and disclosure of joint development arrangements.  Therefore, the Company proposes that in future
filings the Company will classify the amounts received from joint development
partners as research and development expense, rather than revenue.  Under the revised accounting policy, prior to
the commercialization of the product candidate, the Company considers its
joint-development arrangements to be predominately “cost sharing” arrangements
and all joint-development payments will be reflected as an adjustment to research
and development expenses.  This change in
accounting policy and financial reporting will be first reflected in the
Quarterly Report on Form 10-Q for the three and six months ending June 30,
2005. Comparable amounts in prior periods, if any, will be reclassified to
conform to the revised accounting policy.
The Company will also disclose in Management’s Discussion
and Analysis of Financial Condition and Results of Operations the significant
terms of the cost or profit sharing calculations and the amount of joint
development costs for each of the periods presented.

The Company
will continue to reassess the classification of the joint development payments
as its product candidates that are subject to joint development arrangements
approach commercialization.  In the
future, the Company anticipates that its joint development efforts may generate
profits and such arrangements may fundamentally change in nature from “cost
sharing” arrangements to “profit sharing” arrangements.  The Company does not expect that the
classification of profit sharing payments from joint development partners as
expense would fairly present the arrangement or be meaningful to investors
since such payments would reflect the Company’s net share of profits earned
from the collaboration partner’s sales of therapeutic products.

* * * *

Please direct any comments or questions
regarding this filing to H. Ward Wolff at 510-284-6870 or Donald R. Joseph at
510-284-6562.

  Very truly yours,

  /s/ H. Ward Wolff

  Abgenix, Inc.

  By:

  H. Ward Wolff

  Chief Financial Officer and

  Senior Vice President, Finance

  cc:

  William R.
  Ringo,

  President
  and Chief Executive Officer

  Donald R.
  Joseph,

  Senior Vice
  President, General Counsel

  and
  Secretary

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