November 19, 2018

Gil M. Labrucherie
Senior Vice President and Chief Financial Officer
NEKTAR THERAPEUTICS
455 Mission Bay Boulevard South
San Francisco, CA 94158

       Re: NEKTAR THERAPEUTICS
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed March 1, 2018
           File No. 000-24006

Dear Mr. Labrucherie:

        We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

       Please respond to the comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-Q for the nine months ended September 30, 2018

Notes to the Consolidated Financial Statements
Note 6 - License and Collaboration Agreements
Bristol-Myers Squibb (BMS), page 15

1.    On February 13, 2018 you entered into the BMS collaboration agreement to
jointly
      develop and commercialize NKTR-214. You state that you identified two
performance
      obligations, consisting of the delivery of the licenses and your
participation on joint
      steering and other collaboration committees. Your accounting policy on
page 9 states that
      for collaboration arrangements with multiple performance obligations,
such as granting a
      license and performing research and development activities, you allocate
the upfront and
      milestone payments under a relative standalone selling price method. It
is not clear why
      amounts for research and development in the BMS agreement are not
considered a
      performance obligation nor why, as you state on page 15, that you record
cost
      reimbursement payments to you from BMS as a reduction of research and
development
 Gil M. Labrucherie
NEKTAR THERAPEUTICS
November 19, 2018
Page 2
         expense rather than as revenue. It appears to us that your separation,
measurement,
         allocation and classification of amounts related to the BMS agreement
is inconsistent with
         your accounting policy on page 9 and with your accounting for your
agreement with Lilly.
         Please provide us an analysis with reference to authoritative
literature supporting your
         accounting for the BMS agreement. Also, provide us proposed revised
accounting policy
         disclosure to be included in future filings addressing this
inconsistency or tell us why
         revised disclosure is not necessary.
       In closing, 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 Mary Mast at (202) 551-3613 or Lisa Vanjoske at (202)
551-3614 with
any questions.



FirstName LastNameGil M. Labrucherie                         Sincerely,
Comapany NameNEKTAR THERAPEUTICS
                                                             Division of
Corporation Finance
November 19, 2018 Page 2                                     Office of
Healthcare & Insurance
FirstName LastName