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Sorrento Therapeutics,
Inc.

4955 Directors Place

 San Diego, California 92121

August 15, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Mail Stop 3561

Washington, DC 20549

Attention: Sasha Parikh

  Daniel Gordon

Re: Sorrento Therapeutics, Inc.

                                            Form 10-K for Fiscal Year Ended December 31, 2021

                                            Filed March 11, 2022

                                            Form 10-Q for Fiscal Quarter Ended March 31, 2022

                                            Filed May 5, 2022

                                            File No. 001-36150

Ladies and Gentlemen:

This letter responds
to the comments of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
to Henry Ji, Chairman of the Board, CEO and President of Sorrento Therapeutics, Inc., a Delaware corporation (the “Company”),
in the comment letter dated July 25, 2022 (the “Comment Letter”) relating to the Company’s Annual Report
on Form 10-K (File No. 001-36150) for the fiscal year ended December 31, 2021 filed with the Commission on March 11, 2022 and the Company’s
Quarterly Report on Form 10-Q (File No. 001-36150) for the fiscal quarter ended March 31, 2022 filed with the Commission on May 5, 2022.

Set forth below
are the Staff’s comments (in bold italics) and the Company’s responses for each comment, organized as set forth in the Comment
Letter.

Form 10-K for Fiscal Year Ended December
31, 2021

Item 7. Management's Discussion and
Analysis of Financial Condition and Results of Operations

Results of Operations

Comparison of the Years Ended December
31, 2021 and 2020, page 77

 1. Please
                                            quantify each of the factors you noted for the selling, general and administrative expenses
                                            line item that explains the increase and/or decrease from the current period to the respective
                                            prior period, as applicable. For example, you disclosed that selling, general and administrative
                                            expenses for your Sorrento Therapeutics segment increased as compared to the prior fiscal
                                            year and were primarily attributed to higher headcount, professional fees and stock-based
                                            compensation expense as compared to the same period of the prior year.

Please
quantify each of the factors noted.

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U.S. Securities and Exchange Commission

August 15, 2022

Page 2

Sorrento’s response:

The Company respectfully
acknowledges the Staff’s comment, advises the Staff that the Company will enhance its disclosure in future filings to quantify
the noted factors and notes that it has included the following disclosures in the Management’s Discussion and Analysis section
of the Company’s Form 10-Q for the quarter ended June 30, 2022 filed with the SEC on August 15, 2022 (the “Q2 2022
Form 10-Q”).

Selling, General and Administrative
(“SG&A”) Expenses

The decrease in
SG&A expenses in our Sorrento segment during the three months ended June 30, 2022 was attributed to lower professional fees, including
a decrease in legal and consulting costs by approximately $6.4 million, and lower stock-based compensation expenses of $2.9 million.
Personnel costs and infrastructure-related expenses increased by $2.1 million and $1.6 million, respectively, compared to the same period
of the prior year.

The decrease in
SG&A expenses in our Sorrento segment during the six months ended June 30, 2022 was attributed to lower professional fees, including
a decrease in legal and consulting costs, by approximately $4.8 million, and lower stock-based compensation expenses of $5.7 million.
Personnel costs and infrastructure-related expenses increased by $6.9 million and $1.1 million, respectively, compared to the same period
of the prior year.

For the three and
six months ended June 30, 2022, the increases in SG&A expenses in our Scilex segment were attributed to increases in personnel costs
and professional fees compared to the same periods of the prior year.

 2. You
                                            disclosed that research and development expenses for your Sorrento Therapeutics segment increased
                                            by $96.3 million as compared to the prior fiscal year and were primarily driven by higher
                                            headcount and increased clinical development costs spent on advancing your various research
                                            and development programs. As research and development expenses constitute your most significant
                                            expense in the periods presented, please provide us proposed disclosure to be provided in
                                            future filings the costs incurred during each period presented for each of your key research
                                            and development projects. If you do not track your research and development costs by project,
                                            please disclose that fact and explain why you do not maintain and evaluate research and development
                                            costs by project. Provide other quantitative or qualitative disclosure that provides more
                                            transparency as to the type of research and development expenses incurred (i.e. by nature
                                            or type of expense) which should reconcile to total research and development expense on the
                                            Statements of Operations.

Sorrento’s
response:

The Company respectfully
acknowledges the Staff’s comment, advises the Staff that the Company will enhance the disclosure in its future filings to discuss
in more detail the research and development expenses for each period presented and notes that it has included the following disclosures
in the Management’s Discussion and Analysis section of the Q2 2022 Form 10-Q:

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U.S. Securities and Exchange Commission

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Results of Operations

Comparison of the three and six months
ended June 30, 2022 and 2021

Research and
Development (“R&D”) Expenses.

    Three Months Ended June 30,
    Increase (decrease)

    Dollars in thousands
    2022
    2021
    $
    %

    Sorrento segment
    $ 45,876
    $ 52,088
    $ (6,212 )
      (12 %)

    Scilex segment
      2,591
      2,418
      173
      7 %

    Total research and development expenses
    $ 48,467
    $ 54,506
    $ (6,039 )
      (11 %)

    Six Months Ended June 30,
    Increase (decrease)

    Dollars in thousands
    2022
    2021
    $
    %

    Sorrento segment
    $ 106,971
    $ 93,203
    $ 13,768
      15 %

    Scilex segment
      5,222
      5,136
      86
      2 %

    Total research and development expenses
    $ 112,193
    $ 98,339
    $ 13,854
      14 %

R&D expenses
include expenses associated with isolating and advancing human antibody drug candidates derived from our libraries, as well as advancing
our COVID-19, SP-102, SP-103, RTX, oncolytic virus, ADC and oncology programs. Such expenses consist primarily of salaries and personnel-related
expenses, stock-based compensation expense, clinical development expenses, preclinical testing, lab supplies, consulting costs, depreciation
and other expenses. We track external development costs by program; however, we do not allocate laboratory supplies, R&D materials,
personnel costs, share-based payments, facilities costs or other internal costs to specific development programs.

The following table
summarizes our research and development expenses for the three months ended June 30, 2022 and 2021:

    Three months ended June 30,
    Increase (decrease)

    Type of expense
    2022
    2021
    $
    %

    Third party clinical and pre-clinical R&D expenses by program

    Abivertinib
    $ 2,169
    $ 432
    $ 1,737
      402 %

    Resiniferatoxin (“RTX”)
      612
      2,006
      (1,394 )
      -69 %

    COVID-19 therapies and diagnostics, excluding Abivertinib
      4,715
      10,170
      (5,455 )
      -54 %

    Immuno-oncology and other programs
      5,183
      6,944
      (1,761 )
      -25 %

    Total third party clinical and pre-clinical R&D expenses by program
      12,679
      19,552
      (6,873 )
      -35 %

    Laboratory supplies and R&D materials expenses
      2,751
      6,964
      (4,213 )
      -60 %

    Salary, consulting and other personnel costs
      16,140
      12,572
      3,568
      28 %

    Non-cash share-based compensation expenses
      2,947
      5,052
      (2,105 )
      -42 %

    Facility, depreciation and other expenses
      11,359
      7,948
      3,411
      43 %

    Total research and development expenses - Sorrento segment
      45,876
      52,088
      (6,212 )
      -12 %

    Total research and development expenses - Scilex segment
      2,591
      2,418
      173
      7 %

    Total research and development expenses
    $ 48,467
    $ 54,506
    $ (6,039 )
      -11 %

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U.S. Securities and Exchange Commission

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The following table
summarizes our research and development expenses for the six months ended June 30, 2022 and 2021:

    Six months ended June 30,
    Increase (decrease)

    Type of expense
    2022
    2021
    $
    %

    Third party clinical and pre-clinical R&D expenses by program

    Abivertinib
    $ 4,382
    $ 432
    $ 3,950
      914 %

    Resiniferatoxin (“RTX”)
      2,132
      4,339
      (2,207 )
      -51 %

    COVID-19 therapies and diagnostics, excluding Abivertinib
      14,041
      24,120
      (10,079 )
      -42 %

    Immuno-oncology and other programs
      14,575
      12,096
      2,479
      20 %

    Total third party clinical and pre-clinical R&D expenses by program
      35,130
      40,987
      (5,857 )
      -14 %

    Laboratory supplies and R&D materials expenses
      12,280
      10,001
      2,279
      23 %

    Salary, consulting and other personnel costs
      30,821
      18,892
      11,929
      63 %

    Non-cash share-based compensation expenses
      6,136
      7,886
      (1,750 )
      -22 %

    Facility, depreciation and other expenses
      22,604
      15,437
      7,167
      46 %

    Total research and development expenses - Sorrento segment
      106,971
      93,203
      13,768
      15 %

    Total research and development expenses - Scilex segment
      5,222
      5,136
      86
      2 %

    Total research and development expenses
    $ 112,193
    $ 98,339
    $ 13,854
      14 %

Third party clinical
and pre-clinical R&D expenses for our Sorrento segment largely fluctuated as a result of the timing of clinical trial spend and the
timing of our acquisition of ACEA Therapeutics, Inc. (“ACEA”) (Abivertinib), which occurred in June 2021. Salaries,
personnel costs and facilities expenses increased as compared to the same periods in the prior year as we continue expanding our R&D
personnel headcount and infrastructure to support our R&D programs.

Form 10-Q
for the period ended March 31, 2022

Item 4. Controls and Procedures

Evaluation of Disclosure Controls
and Procedures, page 25

 3. We
                                            noted that you did not state management's conclusion with regards to the effectiveness of
                                            your disclosure controls and procedures as of the end of March 31, 2022. As required by Item
                                            307 of Regulation S-K, please disclose management's conclusion with regards to the effectiveness
                                            of your disclosure controls and procedures in future filings.

Sorrento’s
response:

The Company respectfully
advises the Staff that, as required by Item 307 of Regulation S-K, it will disclose management’s conclusion with regards to the
effectiveness of the Company’s disclosure controls and procedures in future filings. The Company further advises the Staff that
it has disclosed management’s conclusion with regards to the effectiveness of the Company’s disclosure controls and procedures
as of March 31, 2022 and as of June 30, 2022 in Part I, Item 4 of the Q2 2022 Form 10-Q.

******

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U.S. Securities and Exchange Commission

August 15, 2022

Page 5

We appreciate the
time that you have taken to review our public filings. Please contact me if you have any further comments or need additional information
with respect to the filing. The Company’s future filings will reflect the responses set forth in this letter, as applicable.

Thank you for your assistance.

    SORRENTO THERAPEUTICS, INC.

    By:
     /s/ Elizabeth Czerepak

    Name:
    Elizabeth Czerepak

    Title:
    Executive Vice President and Chief Financial Officer

cc: Andy
                                            Kimball, Ernst & Young LLP

  Jeffrey T. Hartlin, Paul Hastings LLP

  Samantha H, Eldredge, Paul
                                            Hastings LLP

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