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Response Letter

 WILMER CUTLER PICKERING

     HALE AND DORR LLP

Cynthia T. Mazareas

 60 STATE STREET

 BOSTON, MA
02109

 +1 617 526 6393

 +1 617 526 5000 fax

 cynthia.mazareas@wilmerhale.com

 September 28, 2005

 Pursuant to Regulation §200.83 (Rule 83) of the Freedom of Information Act, this letter omits confidential information included in the unredacted version of this
letter delivered to the Securities and Exchange Commission, Division of Corporation Finance. Asterisks denote such omissions.

 BY ELECTRONIC SUBMISSION

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, NE

Washington,
D.C. 20549

Attention:
Joseph Roesler

Re:
Curis, Inc.

Form 10-K for Fiscal Year Ended December 31, 2004 (“Form 10-K”)

Form 10-Q for Quarter Ended March 31, 2005 (“Form 10-Q”)

File No. 000-30347

 Dear Mr. Roesler:

 On behalf of Curis, Inc. (“Curis” or the “Company”), set forth below are the responses to comments contained in a letter dated August 22, 2005
(the “August Letter”) from Jim B. Rosenberg, of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to Mr. Michael P. Gray, Vice President of Finance and Chief Financial
Officer of Curis relating to the Company’s Form 10-K and Form 10-Q. The response contained herein is based upon information provided to Wilmer Cutler Pickering Hale and Dorr LLP by the Company. The response is keyed to the numbering of the
comments in the August Letter and to the headings used in the August Letter.

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

 Genentech Collaboration Accounting

 BALTIMORE

BEIJING

BERLIN

BOSTON

BRUSSELS

LONDON

MUNICH

 NEW YORK

NORTHERN VIRGINIA

OXFORD

PALO ALTO

WALTHAM

WASHINGTON

 Securities and Exchange Commission

 September 28, 2005

 Page 2

1.
We have evaluated your June 20, 2005 response 3 as it relates to your policy of charging the excess of costs incurred over cumulative revenues recognized against deferred
revenue. The effect of this policy appears to be to accelerate the timing of revenue recognition such that incurred costs have no impact on the income statement in the period in which they are incurred. It does not appear that the income
characterization guidance in EITF 01-9 provides a basis for changing the timing of revenue recognition. Please advise.

 Response:

 The
Company respectfully notes your comment and the additional factors discussed during the Company’s teleconferences with the Staff on August 9, 2005 and August 18, 2005.****************************************************

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 The Company supplementally notes that the Company’s policy was not intended to accelerate revenue recognition. Rather, it was the Company’s
interpretation of the guidance in EITF 01-9 with respect to how a reduction in selling price, resulting from its payments to Genentech, should be reflected in its financial statements.

2.
In our telephone conferences on August 9, 2005 and August 18, 2005, you indicated that you recognize the $4 million in maintenance fees over the performance period. Please
help us understand why each of the maintenance fees does not represent a substantive milestone.

 Securities and Exchange Commission

 September 28, 2005

 Page 3

 Response:

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 More specifically, the June 2003 Genentech agreement provided
for a $5 million up-front fee, two $2 million maintenance fee payments payable in June 2004 and June 2005, respectively, milestone payments on the achievement of specified clinical developmental and drug approval objectives and royalties on product
sales. The maintenance fee payments, while generally associated with the research and development services to be provided through 2005 and the steering committee obligations, are not specifically tied to the achievement of any developmental
objectives.

 In addition, the maintenance fee payments were
contractually committed provided only that Genentech did not terminate the agreement during the first two years of the arrangement as the result of an uncured breach of any material term of the agreement by the Company (or due to the Company’s
insolvency). *****

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 Securities and Exchange Commission

 September 28, 2005

 Page 4

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3.
Please analyze for us why it is appropriate to treat the December 2004 amendment as an arrangement separate and apart from the June 2003 arrangement rather than as a modification of
the June 2003 arrangement. We understand from our telephone conferences on August 9, 2005 and August 18, 2005 that the December 2004 amendment was not contemplated at the time the June 2003 arrangement was entered into and therefore given
the time elapsed between the June 2003 arrangement and its amendment you do not believe that the presumption in EITF 00-21, paragraph 2 has been met. However, we also note that the December 2004 amendment appears to change the rate per full time
equivalent implicit in the June 2003 arrangement through the acceleration of the $2 million cash payment originally due in June 2005. That is, the December 2004 amendment appears to modify the June 2003 arrangement rather than provide for
incremental services. In these circumstances, it is unclear why the December 2004 amendment is accounted for as a unit of accounting separate and apart from the June 2003 single unit of accounting. In addition, please clarify to us what role the
joint steering committee has in the additional eight full-time equivalents provided in the December 2004 amendment.

 Response:

 The
Company respectfully notes your comment. **********

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 EITF 00-21 provides guidance relating to the separability of
deliverables included in an arrangement that obligates a vendor to provide more than one product or service (and that is not subject to the scope of other specific accounting literature). Paragraph 2 of EITF 00-21 states that “separate
contracts with the same entity or related parties that are entered into at or near the same time are presumed to have been negotiated as a package and should, therefore, be evaluated as a single arrangement in considering whether there are one or
more units of accounting. That presumption may be overcome if there is sufficient evidence to the contrary.”

 Pursuant to the original June 2003 agreement, in exchange for the license and the research and steering committee services, Genentech paid a $5 million
up-front license payment and agreed to pay a total of $4 million in maintenance fees. ************

 Securities and Exchange Commission

 September 28, 2005

 Page 5

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 Pursuant to the terms of the June 2003 collaboration, during the initial two-year term of the research program, the Company agreed to assign no fewer than eight FTEs to the program. During the period from June 2003
until June 2004, the Company dedicated FTEs in excess of the minimum eight FTE requirement in order to build preclinical data that the Company expected would increase the likelihood of the successful preclinical development of the technology under
the collaboration. After the conclusion of the first year of the collaboration, the Company asked Genentech to pay for an additional eight FTEs, in return for which the Company would provide research services and xenograft tumor samples to Genentech
on a best-efforts basis (not subject to any acceptance criteria) through June 2005. These xenograft tumor samples are a by-product of the research services and consist of primary human tumor samples that have been implanted and grown in mouse
models. In anticipation of the execution of a formal written agreement, the Company committed an additional eight FTEs to the program beginning in June 2004. On December 20, 2004, the Company and Genentech entered into the expected amendment to
the June 2003 collaboration agreement. Genentech agreed to fund sixteen FTEs at a rate of $250,000 per year per FTE from June 2004 until June 2005, for a total of $4 million. Under the original agreement, during the second year of the collaboration,
the Company was obligated to dedicate 8 FTEs to the collaboration and Genentech would have paid the Company $2 million (which implies a per-FTE rate of $250,000 that is equal to the per-FTE rate included in the amendment). Genentech agreed to pay $2
million in December 2004 and eliminated the $2 million maintenance fee that was due in June 2005 under the original arrangement. In substance, the amendment provided an additional $2.1 million of funding to the Company (including $250,000 for each
of eight incremental FTEs plus $100,000 for the xenograft tumor samples) during the period of June 2004 through June 2005.

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 Securities and Exchange Commission

 September 28, 2005

 Page 6

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 The eight incremental FTEs are supporting the objectives of the research program under the direction of the steering
committee.

4.
In our telephone conferences on August 9, 2005 and August 18, 2005 you indicated that you recognized the right to receive $4 million in maintenance fees as a financial
asset on the date the June 2003 agreement was signed. You indicated that you believed these fees represented deferred payments contingent solely on the expiration of time because the contract did not explicitly link these fees to any particular
performance under the contract. You also indicated that if Curis failed to provide the services specified in the June 2003 arrangement that Curis would not be entitled to the $4 million maintenance fee notwithstanding the absence of an explicit link
between these performance provisions and the $4 million in maintenance fees. Under these circumstances, it is unclear why you believe the right to receive $4 million in maintenance fees represents a financial asset on the date the June 2003
agreement was signed. Please advise.

 Response:

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5.
 We note from your disclosures on page 70 of your December 31, 2004 Form 10-K that you sold 1,323,835 shares of common stock to Genentech for $3.5 million on
June 11, 2003 as partial consideration for the rights and licenses granted to Genentech under the Collaboration Agreement. We also understand from our telephone conference on August 9, 2005 that the $2.644 purchase price of the common
stock sold to Genentech was based on the average closing share price for 30 trading days preceding June 11, 2003, which you believe approximates fair value. Since the common stock was issued as part of a transaction to sell goods or services to
Genentech, it appears that such issuance should be measured and recognized in accordance with EITF 96-18 and classified in accordance with EITF 01-9. Please give us your analysis of both the requirement under EITF 96-18/Statement 123 to use the
quoted market price of the common stock if the common stock is more reliably measurable and the discussion prior to example 4 in EITF 01-9, Exhibit 01-9B. In your analysis, please reconcile the value you attributed to the common stock with the
quoted market price of the common stock on the EITF 96-18 measurement date. If you believe the difference between the $3.5 million value you attributed to the common stock and the fair value of that common stock dete