SecProbe.io

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                          Willkie Farr & Gallagher LLP
                               787 Seventh Avenue
                               New York, NY 10019

April 18, 2005

VIA EDGAR AND FEDEX
-------------------

Ms. Cecilia D. Blye
Chief, Office of Global Security Risk
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington D.C. 20549-0405

RE:  Pharmion Corporation (File No. 0-50447)

Dear Ms. Blye:

     On behalf of Pharmion Corporation (the "Company"), set forth below is the
Company's response to the comment of the staff (the "Staff") of the Securities
and Exchange Commission (the "Commission") contained in your letter, dated March
30, 2005, to Mr. Patrick J. Mahaffy, President and Chief Executive Officer of
the Company.

1.   Comment: We note that on page 14 of your 10-K you state that your products
     are marketed in Syria through a third party distribution network. In light
     of the fact that Syria has been identified by the U.S. State Department as
     a state sponsor of terrorism, and is subject to economic sanctions
     administered by the U.S. Treasury Department's Office of Foreign Assets
     Control, please describe for us the extent of the sales and marketing
     activity with respect to your products in Syria, including the dollar
     amount of such sales; the materiality to the Company of the sale and
     marketing of products in Syria; and your view as to whether the fact that
     your products are sold and marketed in Syria pursuant to your agreements
     with third party distributors constitutes a material investment risk for
     your security holders. In preparing your response please consider that
     evaluations of materiality should not be based solely on quantitative
     factors, but should include consideration of all factors, including the
     potential impact of corporate activities upon a company's reputation and
     share value, that a reasonable investor would deem important in making an
     investment decision.

     Response: To date, there have been no sales of the Company's products into
     Syria, nor does the Company anticipate any such sales in the near term.

     The Company's Swiss subsidiary, Pharmion GmbH, is party to a Distribution
     Agreement, dated as of April 1, 2001, with Quadri Pharmaceuticals Store
     L.L.C. ("Quadri"). Quadri is domiciled in the United Arab Emirates.
     Pursuant to that Distribution Agreement, Quadri has the exclusive right to
     market, sell and distribute two of the Company's products, Thalidomide
     Pharmion 50 mg and Vidaza(R), in a territory comprised of a number of
     Middle Eastern countries. Syria is one of the

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Ms. Cecilia D. Blye
April 18, 2005
Page 2

     countries designated as part of the territory covered in the Distribution
     Agreement, and accordingly was listed by the Company on page 14 of its Form
     10-K as a country accessed by its third-party distribution network.

     The Company currently has three products for which it has sales and
     marketing rights outside of the United States: Thalidomide Pharmion 50 mg,
     Vidaza and Refludan(R). The Company's Distribution Agreement does not grant
     Quadri sales or marketing rights to Refludan and, as the Company's sales
     organization does not serve Syria, the Company does not directly or
     indirectly sell or market Refludan in Syria. As for Thalidomide Pharmion 50
     mg and Vidaza, neither has been approved for marketing or sale in Syria,
     nor has the Company submitted an application to the Syrian Ministry of
     Health seeking such approval. In addition, we have been advised that,
     unlike the regulatory authorities in some countries, the Syrian Ministry of
     Health does not provide "compassionate use" or "named patient" exceptions
     to the general prohibition against sales prior to approval. Accordingly,
     until such time as Thalidomide Pharmion 50 mg and Vidaza are approved for
     sale and marketing in Syria, the Company and Quadri are prohibited from
     engaging in either of those activities within Syria. As such, neither the
     Company nor Quadri have marketed or sold any of the Company's products in
     Syria. We have been advised by Quadri that the only business activity
     relating to the Company's products that has been conducted within Syria to
     date was one brief visit to Damascus by an employee of Quadri to assess the
     market potential for the Company's products within Syria.

     In light of the facts set forth above, the Company does not believe that
     the minimal activity of one of its third party distributors within Syria
     presents a material investment risk for its security holders, nor does the
     Company believe that such activity is reasonably likely to have any impact
     on its reputation or share value.

     Although beyond the scope of the Staff's comment, we note that the Company
     is aware of the U.S. Department of Commerce's licensing requirements
     applicable to the sale of certain U.S.-origin goods in Syria. Given that
     its products are human pharmaceutical products, the Company believes that
     the sale and marketing of these products within Syria is exempt from such
     licensing requirements.

                                      *****

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Ms Cecilia D. Blye
April 18, 2005
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     Should members of the Commission staff have any questions or require any
additional information, they should call the undersigned at (212) 728-8456,
Peter H. Jakes of this office at (212) 728-8230 or Thomas Mark of this office at
(212) 728-8667.

Very truly yours,

/s/ Heath L. Golden

Heath L. Golden

cc:  Jack Guggenheim
     Pharmion Corporation
     Peter H. Jakes, Esq.
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