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CORRESP
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BriaCell
Therapeutics Corp.

Suite
300 – 235 West 15th Street

West
Vancouver, BC V7T 2X1

Securities
and Exchange Commission

100
F Street N.E.

Washington,
D.C. 20549

Division
of Corporation Finance

Attention:
Irene Paik, Joseph McCann, Franklin Wyman and Lisa Vanjoske

    November
    27, 2019

    Re:

    BriaCell
    Therapeutics Corp.

    Amendment
                                         No. 1 to Registration Statement on Form F-1

        Filed
        on November 12, 2019

    File
    No. 333-234292

Ladies
and Gentlemen:

BriaCell Therapeutics
Corp. (the “Company”) is hereby responding to the comment of the Staff (the “Staff”) of the Securities
and Exchange Commission (the “Commission”) contained in its letter dated November 22, 2019, with respect to the above
referenced filing with the Commission by the Company.  For ease of review, we have set forth below the Staff’s comment
in italics, followed by the Company’s responses.

Prospectus
Summary

Phase
I/IIA Combination Study of BRIA-IMT™ with KEYTRUDA®..., page 9

    1.
    We
                                         note your revisions in response to our prior comment 2. However, your disclosure in this
                                         section suggests that you are continuing your development work of a combination therapy
                                         with Keytruda. Please substantially revise this section to provide proper context regarding
                                         your Phase I/IIa combination studies with Keytruda, including but not limited to: (i)
                                         removing the graphic on page 10 and providing a brief narrative description of the combination
                                         studies conducted to date to the extent you plan to use this data in your Biologics License
                                         Application; (ii) limiting your disclosure regarding the substantial benefits of Keytruda
                                         to the extent you are not pursuing approval of this combination; (iii) explaining that
                                         you do not have an agreement with Merck for the supply of Keytruda and (iv) disclosing
                                         that you have discontinued studying the combination of Bria-

        IMT™
        with Keytruda.

    Response:
    The Company respectfully acknowledges the Staff’s comment and has revised the F-1 on pages 10, 46, 52, 64 and 67
    to respond to the comment.

Please do not hesitate
to contact the undersigned with any questions or comments regarding this correspondence.

    Sincerely,

    /s/
    William V. Williams

    William
    V. Williams

cc:
(via email)

Jamieson
Bondarenko

Gadi
Levin

Gregory
Sichenzia, Esq.

Avital
Perlman, Esq.

Aaron
Sonshine

Virgil
Z. Hlus