SecProbe.io

December 13, 2013

Via E-mail
Dr. Mark J. Ahn, PhD
President  and C hief Executive Officer
Galena Biopharma, Inc.
4640 SW Macadam Avenue, Suite 270
Portland, Oregon  97239

Re: Galena Biopharma, Inc.
  Form 10-K for Fiscal Year Ended December 31, 201 2
  Filed March 12 , 2013
  Form 10 -Q for the Quarterly Period Ended September 30, 2013
Filed November 6, 2013  and amended on November 7, 2013
File No. 001-33958

Dear  Dr. Ahn:

We have limited our review to only your financial statements and related
disclosures and do not intend to expand our review to other portions of your document s.
In our comment , we ask you to provide us with information so we may better understand
your disclosure.

Please respond to this letter within 10 business days by  providing the requested
information or by advising us when you will provide the requested response.   If you do
not be lieve  the comment applies to your facts and circumstances, please tell us why in
your response.   Please furnish us a letter on EDGAR under the form type label
CORRESP that keys your response  to our comment .

After reviewing the informat ion provided, we may raise additional comments
and/or request that you amend your filing s.

Form 10 -Q for the Quarterly Period Ended September 30, 2013
Notes to Condensed Consolidated Financial Statements (unaudited)
1. Business and Basis of Presentation
Revenue Recognition, page 8

1. In light of you r recent launch of Abstral, please provide us an analysis of each
condition in ASC 605 -15-25-1 that supports that you met each condition .  Also,
provide us an analysis of each of factor in ASC 605 -15-25-3 to demonstrate you
had the ability to make a reasonable estimate of future returns.   Further, provide

Dr. Mark J. Ahn
Galena Biopharma, Inc.
December 13, 201 3
Page 2

 us an analysis supporting that you were able to reasonably estimate provisions for
prompt pay discounts, wholesaler discounts, rebates, chargebacks, patient
assistance program rebates and other deductions .

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing s to be certain that the filing s include  the information the Securities
Exchange  Act of 1934 and all applicable  Exchange Act rules require.  Since the company
and its management are in possession of all facts relating to a company’s disclosure, they
are responsible for the accuracy and adequacy of the disclosures they have made.

 In responding to our comment , please provide  a written statement from the
company acknowledging that:
 the company is responsible for the adequacy and accuracy of the disclosure in the
filing s;
 staff comments or changes to disclosure in response to st aff comments do not
foreclose the Commission from taking any action with respect to the filing s; and
 the company may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the
United States.

Please contact Frank Wyman, Staff Accountant, at (202) 551 -3660  or Joel Parker,
Accounting Branch Chief , at (202) 551 -3651 if you have any questions regarding th e
comment. In this regard, do not hesitate to contact me at (202) 551-3679.

Sincerely,

 /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief
Accountant