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                            September 22, 2021

       Matthew Abernethy
       Chief Financial Officer
       NEUROCRINE BIOSCIENCES INC
       12780 El Camino Real
       San Diego, CA 92130

                                                        Re: NEUROCRINE
BIOSCIENCES INC
                                                            10-K filed February
5, 2021
                                                            Form 8-K filed
August 3, 2021
                                                            Form 8-K filed
February 4. 2021

       Dear Mr. Abernethy:

              We have reviewed your filing and have the following comments. In
some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Fiscal Year Ended December 31, 2020

       Managment's Discussion and Analysis
       Research and Development, page 54

   1.                                                   We have the following
comments on your research and development disclosures:
                                                            Please disclose the
costs incurred during each period presented for each of your key
                                                           research and
development programs. If you do not track your research and
                                                           development costs by
program, please disclose that fact and explain why you do not
                                                           maintain and
evaluate research and development costs by program;
                                                            Notwithstanding the
above bullet, we note that you separately present milestone
                                                           payments, payroll
and benefits, and facilities and other expenses. Given that these
                                                           costs are separately
presented, please explain the nature of the costs you include in
                                                           the Late, Early and
Research and discover stages; and
                                                            Please expand upon
your statement that the increase in R&D expense from 2019 to
                                                           2020 was primarily
the result of increased investment to support advancing your
 Matthew Abernethy
NEUROCRINE BIOSCIENCES INC
September 22, 2021
Page 2
              clinical portfolio to provide greater insight into the drivers of
this increased
              investment.
Form 8-K filed August 3, 2021

Exhibit 99.1, page 1

2.       We note that you have excluded milestone payments received from
licenses and
         collaborations, milestones paid related to licenses and
collaborations, non-cash
         collaboration revenue and acquired in-process research and development
to arrive at non-
         GAAP net income and non-GAAP income per share. We also note that you
have
         excluded milestones paid related to licenses and collaborations to
arrive at non-GAAP
         R&D. Please tell us your consideration of the guidance in Question
100.01 of the Non-
         GAAP Financial Measures Compliance and Disclosure Interpretations for
         these adjustments. In this regard, you disclose in your Form 10-K that
one of your
         business strategies is to utilize strategic alliances to enhance your
development and
         commercialization capabilities. You also provide a risk factor which
indicates that
         you depend on your current collaborators for the development and
commercialization of
         several of your products and product candidates and may need to enter
into future
         collaborations to develop and commercialize certain of your product
candidates.
Form 8-K filed February 4. 2021

Exhibit 99.1
Full Year 2021 Expense Guidnace, page 3

3.       We note that your Combined GAAP R&D and SG&A expenses do not include
any
         potential milestones or in-process research and development costs
associated with current
         collaborations or future business development activities. Given that
these costs should not
         be excluded from your GAAP measure, please address the appropriateness
of this
         presentation. Refer Item 10(e)(1)(B) and tell us how you intend to
revise your disclosures.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Jeanne Baker at 202-551-3691or Terence O'Brien at
202-551-3355 if
you have questions.



FirstName LastNameMatthew Abernethy                              Sincerely,
Comapany NameNEUROCRINE BIOSCIENCES INC
                                                                 Division of
Corporation Finance
September 22, 2021 Page 2                                        Office of Life
Sciences
FirstName LastName