March 28, 2025

Sandip Kapadia
Chief Financial Officer
Harmony Biosciences Holdings, Inc.
630 W. Germantown Pike, Suite 215
Plymouth Meeting, PA 19462

       Re: Harmony Biosciences Holdings, Inc.
           Form10-K for Fiscal Year Ended December 31 , 2024
           Form 8-K Dated February 25, 2025
Dear Sandip Kapadia:

       We have limited our review of your filing to the financial statements
and related
disclosures 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.

Form 8-K Dated February 25, 2025
Exhibit 99.1

1.     We note your non-GAAP adjusted net income includes adjustments for
upfront
       licensing fees, milestone payments and IPR&D charges incurred in
connection with
       asset acquisitions. Please tell us how you determined that these
adjustments do not
       represent normal, recurring, cash operating expenses necessary to
operate your
       business. Refer to Question 100.01 of the Compliance & Disclosure
Interpretations on
       Non-GAAP Financial Measures.



        In closing, 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.
 March 28, 2025
Page 2

       Please contact Eric Atallah at 202-551-3663 or Gary Newberry at
202-551-3761 with
any questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Life Sciences