May 17, 2019

Randoll Sze
Chief Financial Officer
Athenex, Inc.
1001 Main Street, Suite 600
Buffalo, NY 14203

       Re: Athenex, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed March 11, 2019
           File No. 001-38112

Dear Mr. Sze :

       We have reviewed your filing 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.

Form 10-K for the Fiscal Year Ended December 31, 2018

Item 1. Business
Overview - Orascovery platform, page 2

1.    Your disclosure on page 3 states that in a Phase 2 clinical trial of
Oraxol conducted in
      Taiwan, drug-related serious adverse events consisting of grade 4
neutropenia were
      observed in three patients and all recovered completely. It appears,
however, based on
      your disclosure on page 76 that numerous other serious adverse events
have been
      observed for Oraxol as well as your three other product candidates.
Please revise your
      future filings to disclose the frequency with which each type of serious
adverse event
      occurred for each of your product candidates.
 Randoll Sze
FirstName LastNameRandoll Sze
Athenex, Inc.
Comapany NameAthenex, Inc.
May 17, 2019
Page 2
May 17, 2019 Page 2
FirstName LastName
Item 8. Financial Statements and Supplementary Data
Notes to Consolidated Financial Statements
18. Revenue Recognition, page F-25

2.       Your disclosure on page F-26 related to your Oncology Innovation
Platform indicates that
         license revenue is recorded at a point-in-time given your
determination that delivery of the
         intellectual property to the licensee is a distinct performance
obligation. You also disclose
         that you record the associated milestone payment portions of
transaction prices as revenue
         at a point-in-time. Please address the following as it specifically
relates to your License
         and Development Agreement with Almirall, S.A:
           Identify for us the promised goods and/or services under the
agreement;
           Explain to us how you considered the development services you are
required to
             perform in determining that the license was a distinct performance
obligation;
           Quantify for us the total transaction price, how you determined it,
and the amounts
             allocated to the various performance obligations;
           Tell us the method (ASC 606-10-32-8) you use to estimate variable
consideration for
             reaching development and regulatory milestone events and the
nature, amount and
             trigger for each constrained milestone; and
           Provide us your accounting analysis supporting your accounting
policy of recognizing
             milestones at a point-in-time.
        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 Tabatha McCullom at 202-551-3658 or Angela Connell at
202-551-
3426 with any questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Healthcare & Insurance