Via Facsimile and U.S. Mail
Mail Stop 6010


									September 16, 2005


Richard Stewart
Chief Executive Officer
Amarin Corporation plc
7 Curzon Street
London W1J 5HG
England

Re:  	Amarin Corporation plc
      Form 20-F for the Fiscal Year Ended December 31, 2004
      Filed April 1, 2005
      File Number:  000-21392

Dear Mr. Stewart:

	We have reviewed your filing and have the following comment.
We
have limited our review to only your financial statements and
related
disclosure and do not intend to expand our review to portions of
your
documents. Where indicated, we think you should revise your
document
in response to this comment.   If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 20-F for the Fiscal Year Ended December 31, 2004

Item 5. Operating and Financial Review and Prospects

C. Research and Development, page 38
1. We note that you recorded significant amounts of In-Process
Research and Development costs as part of the October 2004
acquisition and that you anticipate incurring significant research
and development costs in the future.

I. Please provide the following disclosures for the acquired
projects:
a. The specific nature and fair value of each significant in-
process
research and development project acquired.
b. The completeness, complexity and uniqueness of the projects at
the
acquisition date.
c. The significant appraisal assumptions, such as:
i. the period in which material net cash inflows from significant
projects are expected to commence;
ii. material anticipated changes from historical pricing, margins
and
expense levels; and
iii. the risk adjusted discount rate applied to the project`s cash
flows.

II. For significant research and development projects including
those
acquired in October 2004 disclose:
a. The costs incurred during each period presented and to date on
the
project.
b. The nature, timing and estimated costs of the efforts necessary
to
complete the projects, and the anticipated completion dates.
c. The risks and uncertainties associated with completing
development
on schedule, and consequences if it is not completed timely.

Regarding II.a., if you do not maintain any research and
development
costs by project, disclose that fact and explain why management
does
not maintain and evaluate research and development costs by
project.
Provide other quantitative or qualitative disclosure that
indicates
the amount of the company`s resources being used on the project.

Regarding II.b., disclose the amount or range of estimated costs
and
timing to complete the phase in process and each future phase. To
the
extent that information is not estimable, disclose those facts and
circumstances indicating the uncertainties that preclude you from
making a reasonable estimate.

	As appropriate, please amend your filing and respond to this
comment within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your response to our comment.
Detailed
cover letters greatly facilitate our review.  Please file your
letter
on EDGAR under the form type label CORRSEP.  Please understand
that
we may have additional comments after reviewing your amendment and
response to our comment.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comment, please provide,
in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Vanessa Robertson, Staff Accountant, at
(202)
551-3649 or Kevin Woody, Accounting Branch Chief, at (202) 551-
3629
if you have any questions regarding the comments.  In this regard,
do
not hesitate to contact me, at (202) 551-3679.


								Sincerely,



								Jim B. Rosenberg
								Senior Assistant Chief
Accountant
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Richard Stewart
Amarin Corporation plc
September 16, 2005
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