November 19, 2018

Charles R. Eyler
Senior Vice President
Puma Biotechnology, Inc.
10880 Wilshire Boulevard
Suite 2150
Los Angeles, CA 90024

       Re: Puma Biotechnology, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed March 9, 2018
           File No. 001-35703

Dear Mr. Eyler:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 10 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 Year Ended December 31, 2017

Risk Factors, page 29

1.    You disclose on page F-12 that your company has three customers who each
accounted
      for 38%, 23% and 13% of your total revenue in 2017. Plesae confirm to us
that in future
      filings you will disclose in the business or risk factors section the
names of these
      customers and their relationship, if any, to your company, and clarify
the extent to which
      you are dependent on these customers. Refer to Item 101(c)(1)(vii) of
Regulation S-K.
 Charles R. Eyler
FirstName LastNameCharles R. Eyler
Puma Biotechnology, Inc.
Comapany 19, 2018
November NamePuma Biotechnology, Inc.
November 19, 2018 Page 2
Page 2
FirstName LastName



Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Research and Development Expenses, page 60

2.       Please tell us whether you track any component of your research and
development
         expenses by drug candidate depicted in the chart on page 5. If so
represent to us that you
         will revise your disclosure in future filings to disaggregate research
and development
         expenses by drug candidate for each period presented. If not, tell us
whether you can
         provide more granular information, perhaps by nature, such as
manufacturing expenses,
         clinical trial costs, preclinical study expenses, etc. in order to
provide more insight into
         your research and development activities. Otherwise tell us why you
cannot provide such
         additional detail or why its disclosure is not warranted.
Non-GAAP Financial Measures, page 61

3.       It appears that you are presenting non-GAAP adjusted net loss and net
loss per share as
         liquidity measures based on your statement that these measures remove
the impact of
         stock-based compensation due to your emphasis on cash burn and, more
specifically, cash
         used in operations. As such, please revise to provide a reconciliation
of adjusted net loss
         to the most directly comparable GAAP measure for a liquidity measure
(i.e., cash flows
         from operations). In addition, please note that non-GAAP liquidity
measures that measure
         cash generated must not be presented on a per share basis. Whether per
share data is
         prohibited depends on whether the non-GAAP measure can be used as a
liquidity
         measure, even if management presents it solely as a performance
measure. Refer to
         Question 102.05 of the updated Non-GAAP Compliance and Disclosure
Interpretation.

Notes to Consolidated Financial Statements
Note 2   Significant Accounting Policies
Inventory, page F-11

4.       You disclose that inventory costs incurred prior to receipt of
regulatory approval are
         charged to research and development costs when incurred. You also
disclose here and in
         comparable disclosure on page 8 of your September 30, 2018 Form 10-Q
that inventories
         on your period end balance sheets are comprised primarily of raw
materials purchased
         subsequent to FDA approval of NERLYNX. Please tell us the following:
           The dollar value of pre-approval inventory costs charged to research
and development
            costs and the calendar years in which those costs were expensed.
           An estimate of what cost of sales as a percentage of product
revenue, net would have
            been for each quarter from the third quarter of 2017 through the
third quarter of 2018
            if you had not charged pre-approval inventory costs to research and
development
            expenses.
 Charles R. Eyler
Puma Biotechnology, Inc.
November 19, 2018
Page 3

             The estimated amount of future product revenue, net from sales of
the zero-cost/low-
             cost inventory (i.e. inventory that excludes costs charged to
expense prior to regulatory
             approval) on hand at September 30, 2018 and the expected period of
time over which
             it will be sold.
       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 SiSi Cheng at 202-551-5004 or Mark Brunhofer at
202-551-3638 with
any questions.



FirstName LastNameCharles R. Eyler                             Sincerely,
Comapany NamePuma Biotechnology, Inc.
                                                               Division of
Corporation Finance
November 19, 2018 Page 3                                       Office of
Healthcare & Insurance
FirstName LastName