Via Facsimile and U.S. Mail
Mail Stop 03-09


April 8, 2005


Mr. Gregory P. Hanson
Chief Financial Officer
Avanir Pharmaceuticals
11388 Sorrento Valley Road
San Diego, CA 92121

Re:	Avanir Pharmaceuticals
	Form 10-K for the fiscal year ended September 30, 2004
	File No. 001-15803

Dear Mr. Hanson:

      We have reviewed your filing and have the following
comments.
We have limited our review of the above referenced filing to only
those issues addressed.  Where our comments call for disclosure,
we
think you should revise your document in response to these
comments
in future filings beginning with your Form 10-K for the fiscal
year
ended September 30, 2005.  In a supplemental letter, please either
confirm that you will comply with these comments in future filings
or, if you disagree, we will consider your explanation as to why
our
comments are inapplicable or a revision is unnecessary.  In some
of
our comments, we ask you to provide us with supplemental
information
so we may better understand your disclosure.  Please provide us
this
letter, that keys your responses to our comments, within 10
business
days of the date of this letter or tell us when you will provide a
response prior to the expiration of the 10-day period.  Detailed
letters greatly facilitate our review.  Please file your letter on
EDGAR under the form type label CORRESP.  Please understand that
we
may have additional comments after reviewing your responses to our
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.







Form 10-K for the fiscal year ended September 30, 2004

Selected Consolidated Financial Data, page 21

1. Please include gross profit in your selected quarterly
financial
data as required by Item 302 of Regulation S-K.

Management`s Discussion and Analysis

Liquidity and Capital Resources, page 33

2. Your discussion of your license agreement with IriSys Research
and
Development, LLC includes references to payments that you will
potentially make related to achievement of milestones and
royalties.
Please assess whether these milestone payments and royalties meet
the
criteria of a purchase obligation and if these milestone payments
and
royalties should be shown in the contractual obligations table
under
Item 303(a)(5) of Regulation S-K.  Include explanatory footnotes
to
this table as necessary to provide the essential data needed to
understand the timing and amount of your specified contractual
obligations as well as those obligations that have been excluded
from
the table. If as a result of that assessment, you do not include
these payments in the table, please expand your liquidity and
capital
resources disclosures to discuss the amount and timing of event
milestone and royalty commitments that are reasonably likely to be
paid.  Please refer to section IV of Financial Reporting Release
72.

Notes to Consolidated Financial Statements

Note 2.  Summary of Significant Accounting Policies

Revenue Recognition, page F-14

3. Please tell us and expand your disclosure to include your
revenue
recognition policy for product sales, including any related return
policy.  Please formulate this response to specifically address
how
your policy complies with SAB 101.

4. We note you are deferring the revenue received from the sale of
rights to future royalties to Drug Royalty USA because of
continuing
involvement in earning the royalties.  Please provide us your
analysis of the required revenue recognition for this transaction
and
tell us what continuing involvement you have with GlaxoSmithKline
in
earning future royalty revenues.


*    *    *    *





	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors 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 connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; 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.

   In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Dana Hartz, Staff Accountant, at (202) 942-
2976
or Lisa Vanjoske, Assistant Chief Accountant, at (202) 942-1972 if
you have questions regarding the comments.  In this regard, do not
hesitate to contact me, at (202) 942-1803.

								Sincerely,


								Jim B. Rosenberg
								Senior Assistant Chief
Accountant
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Mr. Hanson
Avanir Pharmaceuticals
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