September 16, 2024

Peter Pfreundschuh
Chief Financial Officer
Y-mAbs Therapeutics, Inc.
230 Park Avenue
Suite 3350
New York, NY 10169

       Re: Y-mAbs Therapeutics, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2023
           File No. 001-38650
Dear Peter Pfreundschuh:

       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 10-K for Fiscal Year Ended December 31, 2023
Revenue Recognition
Product revenue, net, page 152

1.     We note that you recognize revenue from sales of DANYELZA at a point in
time, which
       generally occurs upon receipt at the end-user hospital for sales in the
United States, and
       upon delivery to the distributors for sales in the international
territories. Please address
       the following:

              Explain the key differences between your U.S and international
distribution
            agreements and the basis for revenue to be recognized at different
points in time.
              Explain who you have identified as your customer under ASC 606 in
your U.S.
            distributor agreements.
              Clarify who you ship your products to and who controls your
product prior to receipt
            at the end-user hospital.
 September 16, 2024
Page 2

             Tell us if your U.S. distributors have unconditional return
rights.
             Tell us if your U.S. distributors have an unconditional obligation
to pay for your
           product.

       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 Eric Atallah at 202-551-3663 or Tara Harkins at
202-551-3639 with any
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Life
Sciences