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SEC Company Response from BriaCell Therapeutics Corp. (BCTX, BCTXL, BCTXZ) (CIK 0001610820) (BCTX) — May 15, 2020

BriaCell Therapeutics Corp. (BCTX, BCTXL, BCTXZ) (CIK 0001610820)
Date: May 15, 2020 · CIK: 0001610820 · Accession: 0001493152-20-009239

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File numbers found in text: 333-234292

Date
May 18, 2020
Author
/s/
Form
CORRESP
Company
BriaCell Therapeutics Corp. (BCTX, BCTXL, BCTXZ) (CIK 0001610820)

Letter

BriaCell Therapeutics Corp.

Suite 300 – 235 West 15th Street

West Vancouver, BC V7T 2X1

Securities and Exchange Commission

F Street N.E.

Washington, D.C. 20549

Division of Corporation Finance

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

May 15, 2020

Re:

BriaCell Therapeutics Corp.

Amendment No. 7 to Registration Statement on Form F-1

Filed May 18, 2020

File No. 333-234292

Ladies and Gentlemen:

BriaCell Therapeutics Corp. (the “Company”) is hereby filing Amendment No. 7 to its Registration Statement on Form F-1/ Amendment No. 7 has been revised to reflect i) recent developments, ii) the Company’s financials for the fiscal quarter ended January 31, 2020 and iii) the assumed public offering price per Common Unit and Pre-funded Unit of $6.33 (the “Offering Price”). The Offering Price was not determined by any particular formula but rather through negotiations between the Company and the underwriter.

We hope the foregoing answers are responsive to your comments. Please do not hesitate to contact our counsel at (212) 930-9700 with any questions or comments regarding this correspondence.

Sincerely,
/s/
William V. Williams

Show Raw Text
CORRESP
1
filename1.htm

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

    May
    15, 2020

    Re:

    BriaCell
    Therapeutics Corp.

    Amendment
        No. 7 to Registration Statement on Form F-1

        Filed
        May 18, 2020

    File
    No. 333-234292

Ladies
and Gentlemen:

BriaCell
Therapeutics Corp. (the “Company”) is hereby filing Amendment No. 7 to its Registration Statement on Form F-1/ Amendment
No. 7 has been revised to reflect i) recent developments, ii) the Company’s financials for the fiscal quarter ended January
31, 2020 and iii) the assumed public offering price per Common Unit and Pre-funded Unit of $6.33 (the “Offering Price”).
The Offering Price was not determined by any particular formula but rather through negotiations between the Company and the underwriter.

We
hope the foregoing answers are responsive to your comments. Please do not hesitate to contact our counsel at (212) 930-9700 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