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SEC RESPONSE LETTER

VIA FACSIMILE

 January 4, 2006

 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
December 7, 2005 (the “December 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 December Letter and to the headings used in the December Letter.

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

 Genentech Collaboration Accounting

1.
Refer to our comment number 3 and your response. Please revise your proposed disclosure to clearly state that if one milestone is not considered substantive, then the remaining
milestones would also not be considered substantive.

 Response:

 In response to this comment, the Company has further revised its proposed disclosure in Note 1 (Revenue Recognition), which is attached hereto as
Exhibit A. Please be advised that for purposes of the Company’s response to this comment as well as comment No. 2 below, the attached Exhibit A has been marked against the Exhibit A attached to the Company’s
response letter to the Staff dated November 23, 2005.

 Securities and Exchange Commission

 January 4, 2006

 Page 2

2.
Refer to our comment number 4 and your response. We understood from previous discussions that the steering committee services were considered an obligation during the research and
development period, but were considered a right after FDA approval. Please address the following in disclosure-type format:

•

Clarify why the steering committee services would not be considered an obligation during the research and development stage for all products developed, not just the two initial
products or revise your policy to account for all steering committee services consistently as a separate obligation and deliverable under the contract.

•

Clarify whether or not a change in estimate for your period of revenue recognition would be made if you entered into new product development which included participation on a
steering committee.

•

Clarify why the steering committee services become a right after FDA approval.

•

Clarify the term of the steering committee services, any parameters relating to your participation in the steering committee, and whether or not your obligation or participation
differs for the initial two products vs. any other products developed during the life of the agreement.

 Response:

 In response to this comment, the Company has further revised its proposed disclosure in Note 4 (Research and Development Collaborations
Entered into After January 1, 2005), which is attached hereto as Exhibit A.

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

 Very truly yours,

 /s/ Cynthia T. Mazareas / KJ

 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 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 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

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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 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.
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.

 Collaboration agreements may also contain substantive milestone payments. 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;

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•

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 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 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. In addition, the determination that one such payment was not a substantive milestone
would prevent the Company from concluding that subsequent milestone payments were substantive milestones and, as a result, any additional milestone payments would also be considered part of the consideration for the single unit of accounting and
would be recognized as revenue as such performance obligations are performed under either the relative performance or straight-line methods, as applicable.

 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 attributed to the services being
provided under the arrangement and therefore would be recognized 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.

 For revenue generating arrangements where the Company, as a vendor, provides consideration to a licensor or collaborator, as a customer, the Company
applies the provisions of EITF 01-9. EITF 01-9 addresses the accounting for revenue arrangements where both the vendor and the customer make cash payments to each other for services and/or products. A payment to a customer is presumed to be a
reduction of the selling price unless the Company receives an identifiable benefit for the payment and the Company can reasonably estimate the fair value of the benefit received. Payments to a customer that are deemed a reduction of selling price
are recorded first as a reduction of revenue, to the extent of both cumulative revenue recorded to date and of probable future revenues, which include any unamortized deferred revenue balances,

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under all arrangements with such customer and then as an expense. Payments that are not deemed to be a reduction of selling price would be recorded as an
expense.

 Amounts received prior to satisfying the above revenue recognition criteria are recorded as deferred revenue in the accompanying consolidated
balance sheets. Amounts not expected to be recognized during the twelve-month period ended September 30, 2006 are classified as long-term deferred revenue. As of September 30, 2005, the Company has short- and long-term deferred revenue of
$2,152,000 and $7,291,000, respectively, related to its collaborations.

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 (4) RESEARCH AND DEVELOPMENT COLLABORATIONS ENTERED INTO PRIOR TO JANUARY 1, 2005

 During the third quarter of 2005, the Company updated certain aspects of its disclosures related to its research and development collaborations entered
into prior to January 1, 2005. The updated disclosures are presented within this Note and were previously presented in the Company’s Annual Report on Form 10-K for the year ended December 31, 2004.

 (a) GENENTECH, INC. JUNE 2003 COLLABORATION

 (i) Collaboration Summary

 In June 2003, the Company licensed its proprietary Hedgehog pathway technologies to Genentech for human
therapeutic use. The primary focus of the collaborative research plan has been to develop molecules that inhibit, or antagonize, the Hedgehog pathway for the treatment of various cancers. The collaboration consists of two programs: the development
of a small molecule Hedgehog antagonist formulated for the topical treatment for basal cell carcinoma; and the development of systemically administered small molecule and antibody Hedgehog antagonists for the treatment of certain other solid tumor
cancers. Pursuant to the collaboration agreement, Genentech agreed to make specified cash payments, in