June 26, 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
           Response Letter dated May 31, 2019

Dear Mr. Sze :

        We have reviewed your May 31, 2019 response to our comment letter and
have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.

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

      After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
May 17, 2019 letter.

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

Item 8. Financial Statements and Supplementary Data
Notes to Consolidated Financial Statements
18. Revenue Recognition, page F-25

1.    With respect to the fourth bullet to our comment four, you indicate that
commercial
      development, sales milestones and future royalty payments are subject to
the sales and
      usage-based royalty exception set forth in ASC 606-10-55-65. Please
clarify the nature of
      the commercial development milestone payments and explain how you
determined they
      were subject to the royalty exception. In your response, tell us whether,
and if so,
      how these payments are contingent on the sales to or usage by the
customer.
 Randoll Sze
Athenex, Inc.
June 26, 2019
Page 2

      You may contact Tabatha McCullom at 202-551-3658 or Angela Connell at
202-551-
3426 with any questions.



FirstName LastNameRandoll Sze                         Sincerely,
Comapany NameAthenex, Inc.
                                                      Division of Corporation
Finance
June 26, 2019 Page 2                                  Office of Healthcare &
Insurance
FirstName LastName