July 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
           Form 10-Q for the Quarterly Period Ended March 31, 2018
           Filed May 9, 2018
           File No. 001-36033

Dear Ms. Gala:

       We have reviewed your June 28, 2018 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to
comments in our
June 15, 2018 letter.

Correspondence Filed June 28, 2018

Form 10-Q for the Quarterly Period Ended March 31, 2018
Notes to Condensed Consolidated Financial Statements
3. Collaborative Arrangements, page 12

1.    We acknowledge your response to our prior comment one. Please address the
following:
        Tell us your day one policy and the accounting literature to which you
rely to separate
        and initially measure the various parts of your collaborative
arrangements. Address
 Renee Gala
Theravance Biopharma, Inc.
July 23, 2018
Page 2
             how your determination of "reimbursable program costs" in the
Mylan arrangement as
             a "unit of account" complies with your policy.
             Explain to us why you do not believe that analogy to ASC 606 is
appropriate for
             "reimbursable program costs" related to the Mylan arrangement.
Tell us the
             authoritative literature to which you are analogizing or if there
is no appropriate
             analogy, your reasonable, rational, and consistently applied
accounting policy. Refer
             to ASC 808-10-45-3.
             Reconcile for us your conclusion that the amounts you attribute as
being "transaction
             price" in the Mylan arrangement that you allocate to the delivery
of the license and to
             joint steering committee participation and no
attribution/allocation related to
             "reimbursable program costs" with your accounting policy for
separating and initially
             measuring the various parts of your collaborative arrangements. In
addition, regarding
             future potential milestone amounts that were not included in the
transaction price
             because you determined them to be fully constrained, tell us your
accounting for them
             when they are no longer fully constrained and how that complies
with your separation
             and measurement policy.
2.       Your current disclosure appears to suggest the Collaborative
Arrangements referred to
         within your filing are under the scope of ASC 606. Please confirm to
us that, in future
         filings, you will clarify that you are analogizing to the guidance in
ASC 606.
Janssen Biotech, page 12

3.       Please confirm that in future filings you will separately provide the
total amount of R&D
         costs incurred related to the Janssen agreement, as it would appear
the costs incurred
         related to the Janssen arrangement would be useful to understanding
the extent of the
         work performed and costs aggregated on your income statement. Refer to
ASC 730-20-
         50-1b.
       You may contact Abe Friedman at 202-551-8298 or Jim Rosenberg at
202-551-3679 if
you have any questions.

FirstName LastNameRenee Gala
Comapany NameTheravance Biopharma, Inc.
                                                              Division of
Corporation Finance
July 23, 2018 Page 2                                          Office of
Healthcare & Insurance
FirstName LastName