October 23, 2018 Renee Gala Chief Financial Officer Theravance Biopharma, Inc. PO Box 309 Ugland House, South Church Street George Town, Grand Cayman, Cayman Islands, KY1-1104 Re: Theravance Biopharma, Inc. Form 10-K for the year ended December 31, 2017 Filed February 28, 2018 File No. 001-36033 Dear Ms. Gala: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Healthcare & Insurance