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    New York

    Northern California

    Washington DC

    São Paulo

    London
    Paris

    Madrid

    Tokyo

    Beijing

    Hong Kong

        Sophia Hudson

    Davis Polk & Wardwell LLP

450 Lexington Avenue

New York, NY 10017

        212 450 4762 tel

        212 701 5800 fax

        sophia.hudson@davispolk.com

    June 25, 2018

    Re:

        Entera Bio Ltd.

        Amendment No. 5 to Registration Statement on Form F-1

        Submitted June 15, 2018

        CIK No. 0001638097

        CONFIDENTIAL

Ms. Ada D. Sarmento and Ms. Mary B. Breslin

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549-3628

Dear Ms. Sarmento and Ms. Breslin,

On behalf of our client, Entera Bio Ltd., a company incorporated
in Israel with limited liability (the “Company”), we are responding to the comments from the Staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) relating to Amendment No. 5 to the Company’s
Registration Statement on Form F-1 (the “Registration Statement”) contained in the Staff’s letter dated
June 22, 2018 (the “Comment Letter”). In response to the comments set forth in the Comment Letter, the Company
has revised the Registration Statement and is filing an amended Registration Statement (“Amendment No. 6”) together
with this response letter. We are also sending, under separate cover, a copy of Amendment No. 6 (including newly-filed exhibits)
and three marked copies of the Registration Statement showing the changes to the Registration Statement publicly filed on June
15, 2018.

Set forth below are the Company’s responses to the Staff’s
comments in the Comment Letter. The responses and information below are based on information provided to us by the Company. For
convenience, the Staff’s comments are repeated below, followed by the Company’s response to the comments as well as
a summary of the responsive actions taken. We have included page numbers to refer to the location in Amendment No. 6 where the
revised language addressing a particular comment appears.

    Ms. Ada D. Sarmento,

Ms. Mary B. Breslin

Division of Corporation Finance

U.S. Securities and Exchange Commission
    2
    June 25, 2018

Draft Amendment No. 5 to Registration Statement on Form F-1

Dilution, page 60

 1. Your tabular disclosure illustrating the per share
dilution from the transactions includes a caption titled "Pro forma as adjusted net tangible book value per ordinary share."
Please remove the term, "as adjusted," from this caption in order to conform with the description in the preceding narrative.

 Response: In response to the Staff’s comment, the Company has revised the disclosure on page 60 of the Registration Statement.

Exhibit 5.1, page II-8

 2. Please have counsel revise the opinion to opine that
the warrants are a binding obligation of the company in accordance with Section II.B.1.f of Staff Legal Bulletin No. 19.

 Response: In response to the Staff’s comment, the Company has filed Exhibit 5.2 to the Registration Statement.

Please do not hesitate to contact me at (212) 450-4762, (212)
701-5800 (fax) or sophia.hudson@davispolk.com or Michael Kaplan at (212) 450-4111, (212) 701-5800 (fax) or michael.kaplan@davispolk.com
if you have any questions regarding the foregoing or if I can provide any additional information.

    Very truly yours,

/s/ Sophia Hudson

Sophia Hudson

    cc:

        Via E-mail

        Dr. Phillip Schwartz, Chief Executive Officer

        Mira Rosenzweig, Chief Financial Officer

        Entera Bio Ltd.

        Michael Kaplan, Davis Polk

        Ivan Blumenthal, Mintz Levin