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July 21, 2023
John V. Oyler
Chief Executive Officer
BeiGene, Ltd.
94 Solaris Avenue, Camana Bay
Grand Cayman
Cayman Islands KY1-1108
Re:BeiGene, Ltd.
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed February 27, 2023
File No. 001-37686
Dear John V. Oyler:
            We have limited our review of your filing to the submission and/or disclosures as
required by Item 9C of Form 10-K and have the following comments. In some of our comments,
we may ask you to provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 135
1.We note your statement that as of the date of this Annual Report, no governmental entity
in mainland China or Hong Kong has filed a Schedule 13D or 13G, there are no material
contracts with such foreign governmental party, and there is no such foreign governmental
representative on your Board in connection with your required submission under
paragraph (a). Please supplementally describe any materials that were reviewed and tell us
whether you relied upon any legal opinions or third party certifications such as affidavits
as the basis for your submission. In your response, please provide a similarly detailed
discussion of the materials reviewed and legal opinions or third party certifications relied
upon in connection with the required disclosures under paragraphs (b)(2) and (3).

 FirstName LastNameJohn V. Oyler
 Comapany NameBeiGene, Ltd.
 July 21, 2023 Page 2
 FirstName LastName
John V. Oyler
BeiGene, Ltd.
July 21, 2023
Page 2
2.In order to clarify the scope of your review, please supplementally describe the steps you
have taken to confirm that none of the members of your board or the boards of your
consolidated foreign operating entities are officials of the Chinese Communist Party. For
instance, please tell us how the board members’ current or prior memberships on, or
affiliations with, committees of the Chinese Communist Party factored into your
determination. In addition, please tell us whether you have relied upon third party
certifications such as affidavits as the basis for your disclosure.
3.We note that your disclosures pursuant to Item 9C(b) refer to either “the Company” or
“the Company or its operating subsidiaries.” It is unclear from the context of these
disclosures whether “the Company” is meant to encompass you and all of your
consolidated foreign operating entities or whether in some instances this term refers solely
to BeiGene, Ltd. Please note that Item 9C(b) requires that you provide each disclosure for
yourself and your consolidated foreign operating entities, including variable interest
entities or similar structures. To clarify this matter, please provide the information
required by each subsection of Item 9C(b) for you and all of your consolidated foreign
operating entities in your supplemental response.
4.We note your disclosure provided pursuant to Item 9C(b)(4) that no “officials of the
Chinese government” are members of your board or the board(s) of your operating
subsidiaries and your additional statement that there is no “foreign government
representative” on your board. Please confirm, if true, that no members of your board of
directors or the boards of your consolidated foreign operating entities are officials of the
Chinese Communist Party.
5.With respect to your disclosure pursuant to Item 9C(b)(5), we note that you have included
language that such disclosure is “to the extent known by the Company.” Please
supplementally confirm without qualification, if true, that your articles and the articles of
your consolidated foreign operating entities do not contain wording from any charter of
the Chinese Communist Party.
            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 Kyle Wiley at (202) 344-5791 or Jennifer Thompson at (202) 551-3737
with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc:       Edwin M. O'Connor