| Hampshire International Business Park Basingstoke Hampshire RG24 8EP UK Tel +44 1256 894000 Fax +44 1256 894708 http://www.shire.com |  |
| James Peklenk, Staff Accountant |
| Securities and Exchange Commission |
| 450 Fifth Street, N.W. |
| Washington, D.C. 20549 |
| August 25, 2006 |
| Re: | Shire plc | |
| Form 10-K for Fiscal Year Ended December 31, 2005 | ||
| Filed March 1, 2006 | ||
| File No. 000-29630 | ||
| Item 7: Management’s Discussion and Analysis of Financial Conditionand Results of Operations, page 42 | ||
| Critical Accounting Estimates, page 62 | ||
| (v) Sales Deductions, page 64 |
Dear Mr Peklenk,
As we discussed on the telephone, we are considering our response to the SEC’s comment letter, in respect of the above item.
In order to ensure the completeness and accuracy of our response, we are conducting a detailed review of our general ledger entries for certain sales deductions in 2005, 2004 and 2003.
We anticipate being able to complete this review and provide an updated response to the SEC by Friday September 8th. We trust that this is acceptable.
| Sincerely, |
| /s/ James Bowling |
| James Bowling |
| VP, Group Reporting |
| cc. Angus Russell, Chief Financial Officer |
Shire plc Registered in England 5492592 Registered Office as above