United States securities and exchange commission logo April 22, 2024 Howard Horn Executive Vice President Ultragenyx Pharmaceutical Inc. 60 Leveroni Court Novato, CA 94949 Re: Ultragenyx Pharmaceutical Inc. Form 10-K for Fiscal Year Ended December 31, 2023 File No. 1-36276 Dear Howard Horn: We have limited our review of your filing to the financial statements and related disclosures and have the following comment(s). 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 10-K for Fiscal Year Ended December 31, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations, page 69 1. Please address the following regarding your table of research and development (R&D) expenses on page 75: Tell us and revise your future filings to clearly disclose the extent to which you track any of your R&D expenses at the individual product candidate level, as you previously disclosed in your 2020 Form 10-K. If so, revise your future filings to separately quantify your R&D expenses for amounts tracked by product candidate. Please provide us with your proposed disclosure in your response. 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. Please contact Tracie Mariner at 202-551-3744 or Kevin Vaughn at 202-551-3494 with Howard Horn Ultragenyx Pharmaceutical Inc. April 22, 2024 Page 2 any questions. FirstName LastNameHoward Horn Sincerely, Comapany NameUltragenyx Pharmaceutical Inc. Division of Corporation Finance April 22, 2024 Page 2 Office of Life Sciences FirstName LastName