SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

November 18, 2005

Mr. Michael P. Gray
Vice President of Finance and
Chief Financial Officer
Curis, Inc.
61 Moulton Street
Cambridge, MA 02138

Re:	Curis, Inc.
		Form 10-K for Fiscal Year Ended December 31, 2004
		Form 10-Q for Quarter Ended March 31, 2005

	File No.  000-30347

Dear Mr. Gray:

	We have reviewed the above referenced filings and your
November
9, 2005 response to our letter dated November 1, 2005, and have
the
following comments.  In our comments, we ask you to provide us
with
information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the year ended December 31, 2003

Genentech Collaboration Accounting

1. Refer to comment 1.  We note you plan to revise your accounting
in
future periods.   From our telephone conversations, we understood
that the correction of this accounting policy had no impact on
historical periods.  Please tell us if our understanding is
correct.

2. We note that your proposed disclosure on page A-2 no longer
addresses how you account for a multiple element arrangement that
represents a single unit of accounting if that arrangement
contains
performance obligations that are not on a best efforts basis.  If
you
enter into such arrangements, please revise your proposed
accounting
policy disclosure to address them.
3. Refer to the discussion of substantive milestones on page A-3.
We
understood from telephone discussions with you that if a
performance
bonus does not meet the conditions described on page A-3, then the
resulting payment would not be considered a substantive milestone
and
therefore the resulting payment would be considered part of the
consideration for the single unit of accounting and recognized
over
that unit`s performance period using either the relative
performance
or straight-line methods, as applicable, described on page A-2.
We
also understood from those telephone discussions that if an
arrangement contained multiple performance bonuses and you
determined
that a performance bonus was not a substantive milestone, this
determination would prevent you from concluding that subsequent
performance bonuses were substantive milestones and as a result
those
performance bonuses would also be considered part of the
consideration for the single unit of accounting.  Please tell us
if
our understanding is correct and consider the need to clarify your
proposed disclosure.
4. We note from the revised disclosure that you propose on page A-
8
of your response that the performance period you use to recognize
revenue (i.e. June 2003 through June 2011) only includes Curis`
steering committee performance obligations as they relate to the
first product discovered for each of basal cell carcinoma and
Hedgehog.  However, we also note from the revised disclosure you
propose that the Genentech June 2003 Collaboration is not limited
to
the first product discovered for each of basal cell and Hedgehog,
but
also covers other drugs and that Curis` steering committee
performance obligations extend beyond the first product discovered
for each of basal cell and Hedgehog.  Because Curis has asserted
that
its participation in the steering committee is a right to
participate
and not an obligation to participate only when a drug is in the
manufacturing and selling phase, please clarify for us why the
performance period would exclude Curis` obligation to participate
in
the steering committee while research and development is ongoing
under the arrangement subsequent to the first product approved in
both the basal cell and Hedgehog.
5. Based on our telephone conversation, we confirm our
understanding
that you plan to further revise your disclosure to clarify the
following points:
a. See the last paragraph on page A-1.  You will clarify that you
analyze multiple element arrangements, such as license and
development arrangements, to determine whether the deliverables,
which often include a license and performance obligations such as
research and steering committee services, can be separated or
whether
they must be accounted for as a single unit of accounting.

b. See the last paragraph on page A-2.  You will clarify that if
the
Company is involved in a steering committee as part of a multiple
element arrangement that is accounted for as a single unit of
accounting, the Company assesses whether its involvement
constitutes
a performance obligation or a right to participate.
c. See the first paragraph on page A-9.  You will clarify that you
believe the clinical development and drug approval milestones
under
the Genentech June 2003 collaboration are substantive milestones
because they meet all of the conditions described in your policy.

*    *    *    *

      	Please respond to the comments within 10 business days
or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides the
requested information.  Detailed letters greatly facilitate our
review.  Please file your letter on EDGAR under the form type
label
CORRESP.

	You may contact Joseph Roesler, Staff Accountant, at (202)
551-
3628 or Mary Mast, Senior Accountant, at (202) 551-3613 if you
have
questions regarding the comments. In this regard, do not hesitate
to
contact me, at (202) 551-3679.

								Sincerely,

								Jim B. Rosenberg
								Senior Assistant Chief
Accountant

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Michael P. Gray
Curis, Inc.
November 18, 2005
Page 3

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