United States securities and exchange commission logo July 8, 2020 Christopher Stone Vice President and General Counsel PDL BioPharma, Inc. 932 Southwood Boulevard Incline Village, Nevada 89451 Re: PDL BioPharma, Inc. Preliminary Proxy Statement on Schedule 14A Filed May 5, 2020 File No. 000-19756 Dear Mr. Stone: 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 Life Sciences cc: Jacob D. Steele