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  June 15, 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 related to critical accounting estimates 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.

In response to the Staff’s comment, the
Company has reassessed whether the nature of the estimates or assumptions for
revenue recognition is material due to the levels of subjectivity and judgment
necessary to account for highly uncertain matters, the susceptibility of such
matters to change, and whether the impact of the estimates and assumptions on
financial condition or operating performance is material.  Accordingly, in response to the Staff’s
comment, the Company will revise future filings to include revenue recognition
as a critical accounting estimate and disclose why our accounting estimates bear the risk of change, how we arrived at
the estimates, how much the estimates have changed in the past, whether the
estimates are reasonably likely to change in the future, and to provide
quantitative information related to the sensitivity of our estimates to change.  The following is an example of how future
filings will be revised in response to the Staff’s comment (underlined language
represents new statements following prior statements in our most recent Form 10-K):

“We enter into revenue arrangements with
multiple deliverables in order to meet our customer’s needs. For example, the
arrangements may include a combination of up-front fees, license payments,
research and development services, milestone payments, future royalties, and
manufacturing arrangements. Multiple element revenue agreements entered into on
or after July 1, 2003 are evaluated under Emerging Issues Task Force No. 00-21,
“Revenue Arrangements with Multiple Deliverables,” or EITF 00-21, to
determine whether the delivered item has value to the customer on a stand-alone
basis and whether objective

and reliable evidence of the fair value of the undelivered item exists.
Deliverables in an arrangement that do not meet the separation criteria in
EITF 00-21 must be treated as one unit of accounting for purposes of
revenue recognition. Generally, the revenue recognition guidance applicable to
the final deliverable is followed for the combined unit of accounting. For
certain arrangements, the period of time over which certain deliverables will
be provided is not contractually defined. Accordingly, management is required
to make estimates and assumptions that affect the amounts reported in the
financial statements and accompanying notes.
For example, during 2004, we recognized revenue of approximately $0.5
million related to arrangements for which the period of time over which the
research will be performed was not contractually defined.  For these arrangements, we are amortizing
up-front fees over the 15-  to 20-month
period of time defined in the research plan mutually established by us and our
customer.  As of December 31, 2004,
approximately $0.2 million remained in deferred revenue related to these
arrangements.  In addition, during 2004,
we recognized revenue of approximately $0.7 million related to an arrangement
for which the period of time of continuing obligation is dependent upon the
timing of product commercialization.  The
length of time necessary to complete preclinical and clinical testing, and to
obtain marketing approval to commercialize a product, varies substantially
according to the type, complexity, novelty and intended use of the product
candidate and many factors may delay commercialization.  If the date of the product commercialization
is delayed by one year, the amount of revenue recognized in 2005 would be approximately
$0.6 million, as opposed to $0.7 million under our current estimate.  As of December 31, 2004, approximately
$4.2 million remained in deferred revenue related to this arrangement.  To date, there has not been a change in an
estimate or assumption made in the past that had a material impact on revenue
recognition.”

* * * *

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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