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                                                           June 18, 2025

Christopher Prentiss
Chief Financial Officer
MannKind Corporation
1 Casper Street
Danbury, Connecticut 06810

        Re: MannKind Corporation
            Form 10-K for the Fiscal Year Ended December 31, 2024
            Filed February 26, 2025
            File No. 000-50865
Dear Christopher Prentiss:

       We have reviewed your June 5, 2025 response to our comment letter and
have the
following comment.

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

       After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our May 16,
2025 letter.

Form 10-K for the Fiscal Year Ended December 31, 2024
Notes to Consolidated Financial Statements
11. Collaborations, Licensing and Other Arrangements, page 94

1.     We note your responses to prior comments one and two. Please address the
following
       as it relates to collaboration and services revenue earned under your
CSA with UT:
           Quantify, for each period presented, the portion of revenues earned
from product
            sales to UT on a cost plus margin basis as well as the portion of
previously
            deferred revenue recognized for pre-production activities under the
CSA.
           Describe and quantify the key factors underlying the increase in
product sales to
            UT, including changes in production cost, margin and facility
utilization expense
            and any other variables as referenced in the CSA.
           Provide a rollforward of your deferred revenue balance, similar to
the disclosure
            provided on page 94, for each performance obligation.
 June 18, 2025
Page 2

             Explain your consideration of providing the disclosures required
by ASC 606-10-
           50-13 for each of your remaining performance obligations.
             Disclosure in your December 31, 2023 Form 10-K indicates that the
significant
           increase in deferred revenue during 2023 was primarily related to
the capital
           improvements for the expansion of your manufacturing facility and
that you
           determined that the revenue recognition associated with the capital
improvements
           should be combined with the manufacturing services performance
obligation.
           Clarify how this additional deferred revenue was determined. For
example, did
           UT fund the cost of your facility expansion and if so, how much of
your deferred
           revenue balance relates to such expansion?
             Provide us with an unredacted copy of the CSA, as amended. Please
discuss with
           staff how to submit such materials.

       Please contact Frank Wyman at 202-551-3660 or Angela Connell at
202-551-3426 if
you have questions regarding comments on the financial statements and related
matters.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Life
Sciences
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