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SEC RESPONSE LETTER

 VIA FACSIMILE

 November 9, 2005

 Securities and Exchange Commission

 Division of Corporation Finance

 Judiciary Plaza

 450 Fifth Street, N.W.

 Washington, DC 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 Company’s responses to comments contained in a letter dated November 1, 2005 (the “November 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 November Letter and to the headings used in the November Letter.

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

 Genentech
Collaboration Accounting

1.
We have read your response to comment 1. For the reasons cited in our October 26, 2005 conference call we continue to believe the income classification guidance in EITF 01-9
cited in your September 28, 2005 response does not provide a sufficient basis to offset income statement debits against deferred revenue. Please provide revised disclosures in disclosure-type format so we may evaluate your proposed disclosures.

 Response:

 In response to this comment, the Company intends to revise its accounting in
future periods under EITF 01-9 for revenue generating arrangements

 Securities and Exchange Commission

 November 9, 2005

 Page 2

where the Company, as a vendor, provides consideration to a licensor or collaborator, as a customer. Accordingly, the Company intends to revise the related
disclosures in the notes to its financial statements in future filings and, specifically, has attached to this letter as Exhibit A the proposed revised disclosures for Note 1 (Revenue Recognition) (“Note 1”) and Note 4
(Research and Development Collaborations Entered Into Prior to January 1, 2005) (“Note 4”). Specifically, the Company has further revised the second to last paragraph in Note 1 and has also included a similar disclosure in the last
paragraph of the “Accounting Summary” section of Note 4(a).

 Please be advised that for purposes of the Company’s response to this comment as well as comment Nos. 2 and 5 below, the attached Exhibit A has been marked against the Exhibit A attached to the
Company’s response letter to the Staff dated September 23, 2005.

2.
We have read the proposed revenue recognition disclosures in your response to comment 6 and based on the October 26, 2005 conference call we understand you are drafting new
disclosures on revenue recognition to better clarify in what circumstances you use the relative performance method, the straight line method, the deliverable method and the substantive milestone method. We will re-evaluate your policy once we
receive your proposed disclosures.

 Response:

 In response to this comment, the Company has further
revised its revenue recognition disclosures in Note 1. The Company has attached as Exhibit A the proposed revised disclosures to Note 1.

3.
In your response to comment 4 you stated that you will provide us a SAB 99 analysis. We will evaluate your response and your proposed disclosures once we receive your SAB 99
analysis.

 Response:

 In response to this comment, the Company has supplementally provided to the
Staff its SAB 99 analysis of the materiality of its error in recording $4.0 million in maintenance fees as receivables and deferred revenue at the outset of the Genentech collaboration in June 2003.

4.
 We have read your response to comment 5 and we are unable to concur with you that taking an approximately 37% discount of the quoted market price is appropriate. We
believe the quoted market price of the common stock on the EITF 96-18 measurement date is the best evidence of the value of stock. We also believe that restrictions imposed do not provide a basis for valuing the stock at a price other than the
quoted market price

 Securities and Exchange Commission

 November 9, 2005

 Page 3

and we do not believe the example provided in your response is comparable to the fact pattern presented. Please advise.

 Response:

 After further consideration of the Staff’s comment and our discussion
during the October 26, 2005 conference call, the Company has now determined that it will modify its accounting for the sale of common stock to Genentech and Wyeth so that it is based on the quoted market prices as of the respective transaction
dates. As a result of this determination, the Company has supplementally provided to the Staff its SAB 99 analysis of the materiality of its errors in recording the common stock sales to Genentech and Wyeth based upon a trailing average closing
price rather than the quoted market price on the date of sale.

 Also as a result of this determination, the Company intends to revise the related disclosures in the notes to its financial statements in future filings and, specifically, has revised the disclosures in Note 4(a)(i) and (ii) and
4(c)(i) and (ii) set forth in Exhibit A attached hereto

5.
We have read the proposed disclosures in your response to comment 8. We refer to the Genentech accounting summary disclosures in which you state that the “second $2,000,000
maintenance payment was eliminated as part of an amendment.” The term “eliminated” seems to imply that the receivable was written-off when in fact it was replaced with another amount per the amendment. Please provide revised
disclosure in disclosure-type format so we may evaluate your proposed disclosures.

 Response:

 In response to this comment, the Company has revised the disclosures in Note 4(b) to remove the word “eliminated” from its revenue
recognition disclosure and to clarify that the second $2,000,000 maintenance payment due under the June 2003 arrangement was replaced by a $2,000,000 payment made to the Company for research services in December 2004 with no economic impact arising
from the replacement f one payment for the other. The Company has attached the proposed revised disclosures for Note 4(b) to this letter as Exhibit A.

 If you require any additional information, please telephone the undersigned at the telephone number indicated above.

 Securities and Exchange Commission

 November 9, 2005

 Page 4

 Please be advised that it is the Company’s intention to include the updated disclosures set forth in Exhibit A
and the other modifications to its financial statements in its Quarterly Report on Form 10-Q for the Quarter ended September 30, 2005, which the Company is required to file with the SEC on or before November 9, 2005. Accordingly, the
Company would appreciate the opportunity to review any further comments or revisions with the Staff at its earliest convenience prior to such filing.

Sincerely,

/s/    CYNTHIA T.
MAZAREAS

Cynthia T. Mazareas

Cc:
Michael P. Gray

 Exhibit A

(1) REVENUE RECOGNITION

 During the third quarter of 2005, the Company updated its disclosure relating to its revenue recognition policies that were previously presented in the Company’s Annual Report on Form 10-K for the year ended
December 31, 2004. In addition, in the third quarter of 2005, the Company recorded adjustments identified during the preparation of the financial statements for the quarter to correct errors in recording the fair value of shares issued in
connection with our collaborations with Genentech and Wyeth. The shares were valued using a price based on a trailing average of closing prices, pursuant to the terms of the stock purchase agreements. The Company has determined that it should have
valued the shares using the quoted market price on the dates of issuance and, as a result, additional paid-in capital was understated and deferred revenues were overstated. The effects of these adjustments was to increase additional paid-in-capital
by $1,629,000, decrease noncurrent deferred revenue by $1,169,000 and to reverse $460,000 of revenue in the third quarter of 2005 to correct for the cumulative overstatement of revenues from June 2003 through June 30, 2005. The impact of these
errors, if recorded in the periods to which they related, would not effect the net loss per share previously reported by the Company for any prior year or quarter, nor otherwise have a material impact on previously reported financial information. In
addition, the Company does not believe that the impact of these adjustments is material to the financial statements for the quarter ended September 30, 2005 or to the projected results of operations for the year ending December 31, 2005.

 The Company’s business strategy includes entering into collaborative
license and development agreements with biotechnology and pharmaceutical companies for the development and commercialization of the Company’s product candidates. The terms of the agreements typically include non-refundable license fees, funding
of research and development, payments based upon achievement of clinical development milestones and royalties on product sales. The Company follows the provisions of the Securities and Exchange Commission’s Staff Accounting Bulletin (SAB)
No. 104 (SAB No. 104), Revenue Recognition, Emerging Issues Task Force (EITF) Issue No. 00-21 (EITF 00-21), Accounting for Revenue Arrangements with Multiple Deliverables, EITF Issue No. 99-19 (EITF 99-19), Reporting
Revenue Gross as a Principal Versus Net as an Agent, and EITF Issue No. 01-9 (EITF 01-9), Accounting for Consideration Given by a Vendor to a Customer (Including a Reseller of the Vendor’s Products).

 Non-refundable license fees are recognized as revenue when the Company has a contractual
right to receive such payment, the contract price is fixed or determinable, the collection of the resulting receivable is reasonably assured and the Company has no further performance obligations under the license agreement. Multiple element
arrangements, such as license and development arrangements are analyzed to determine whether the elements, the license and the performance obligations, can be separated or whether they must be accounted for as a single unit of accounting in
accordance with EITF 00-21. The Company recognizes up-front license payments as revenue upon delivery of the license only if the license has standalone value and the fair value of the undelivered performance obligations, typically including research
or steering committee services, can be determined.

If the fair value of the undelivered performance obligations can be determined, such obligations would then be accounted for separately as performed. If the
license is considered to either (i) not have standalone value or (ii) have standalone value but the fair value of any of the undelivered performance obligations cannot be determined, the arrangement would then be accounted for as a single
unit of accounting and the license payments and payments for performance obligations are recognized as revenue over the estimated period of when the performance obligations are performed.

 Whenever the Company determines that an arrangement should be accounted for as a single unit of accounting, it must determine the period
over which the performance obligations will be performed and revenue will be recognized. Revenue will be recognized using either a relative performance or straight-line method. The Company recognizes revenue using the relative performance method
provided that the Company can reasonably estimate the level of effort required to complete its performance obligations under an arrangement and such performance obligations are provided on a best-efforts basis. Direct labor hours or full-time
equivalents are typically used as the measure of performance. Revenue recognized under the relative performance method would be determined by multiplying the total payments under the contract, excluding royalties and payments contingent upon
achievement of substantive milestones, by the ratio of level of effort incurred to date to estimated total level of effort required to complete the Company’s performance obligations under the arrangement. Revenue is limited to the lesser of the
cumulative amount of payments received or the cumulative amount of revenue earned, as determined using the relative performance method, as of each reporting period.

 If the Company cannot reasonably estimate the level of effort required to complete its performance obligations under an arrangement and the
performance obligations are provided on a best-efforts basis, then the total payments under the arrangement, excluding royalties and payments contingent upon achievement of substantive milestones, would be recognized as revenue on a straight-line
basis over the period the Company expects to complete its performance obligations. Revenue is limited to the lesser of the cumulative amount of payments received or the cumulative amount of revenue earned, as determined using the straight-line
basis, as of the period ending date.

 Significant management judgment is
required in determining the level of effort required under an arrangement and the period over which the Company is expected to complete its performance obligations under an arrangement. In addition, if the Company is involved in a steering committee
under a research arrangement, the Company assesses whether its involvement constitutes a performance obligation or a right to participate. Steering committee services that are not inconsequential or perfunctory and that are determined to be
performance obligations are combined with other research services or performance obligations required under an arrangement, if any, in determining the level of effort required in an arrangement and the period over which the Company expects to
complete its aggregate performance obligations.

 A-2

 Collaboration agreements may also contain substantive milestones. Substantive milestone payments are considered to be
performance bonuses that are recognized upon achievement of the milestone only if all of the following conditions are met:

•

the milestone payments are non-refundable;

•

achievement of the milestone involves a degree of risk and was not reasonably assured at the inception of the arrangement;

•

substantive effort is involved in achieving the milestone;

•

the amount of the milestone payment is reasonable in relation to the effort expended or the risk associated with achievement of the milestone; and,

•

a reasonable amount of time passes between the up-front license payment and the first milestone payment as well as between each subsequent milestone payment.

 Determination as to whether a milestone meets the aforementioned
conditions involves management’s judgment. If any of these conditions are not met, the milestone payment would not be considered a substantive milestone, and the resulting payment would be recognized as revenue as such performance obligations
are performed under either the relative performance or straight-line methods, as applicable, and in accordance with these policies as described above.

 Reimbursement of costs is recognized as revenue provided the provisions of EITF 99-19 are met, the amounts are determinable, and collection of the related receivable is
reasonably assured.

 Royalty revenue is recognized upon the sale of the related
products, provided that the royalty amounts are fixed or determinable, collection of the related receivable is reasonably assured and the Company has no remaining performance obligations under the arrangement. If royalties are received when the
Company has remaining performance obligations, the royalty payments would be attribute