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CORRESP
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CORRESP

 Goodwin Procter LLP

 100 Northern Avenue

Boston, Massachusetts 02210

 VIA EDGAR

 March
25, 2024

 United States Securities and Exchange Commission

Division of Corporation Finance

 Office of Life Sciences

100 F Street, N.E.

 Washington, D.C. 20549-3628

Attention: Jenn Do, Mary Mast, Lauren Hamill and Chris Edwards

Re:
 AVROBIO, Inc.

Registration Statement on Form S-4

Filed February 14, 2024

File No. 333-277048

 Ladies and
Gentlemen,

 On behalf of AVROBIO, Inc. (the “Company”), we are submitting this letter to the Securities and Exchange Commission (the
“SEC”) via EDGAR in response to the comment letter from the staff of the SEC (the “Staff”), dated March 12, 2024 (the “Comment Letter”), pertaining to the Company’s above-referenced
Registration Statement on Form S-4 (the “Registration Statement”). In connection with such responses, the Company is concurrently filing Amendment No. 1 to the Registration Statement (the
“Amended Registration Statement”).

 For your convenience, the Staff’s comments have been reproduced in bold and italics herein with
responses immediately following each comment. Unless otherwise indicated, page references in the reproductions of the Staff’s comments refer to the Registration Statement, and page references in the responses below refer to the Amended
Registration Statement. Capitalized terms used in this letter but otherwise not defined herein shall have the meanings set forth in the Amended Registration Statement.

Registration Statement on Form S-4 Filed February 14, 2024

Cover Page

1.
 It appears that the shares to be sold in the Tectonic pre-closing
private financings are included in the shares to be registered in this registration statement. The investors in the Tectonic pre-closing financing made their investment decision in a private offering and,
therefore, the sale must close privately. Please remove the Tectonic pre-closing financing shares from the registration statement.

Response: The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has revised the filing fee table
filed as Exhibit 107 to the Amended Registration Statement.

 What are the private financings?, page 2

2.
 Please revise this Q&A, the summary risks and risk factors, and elsewhere as appropriate to highlight
that the closing of the merger is not conditioned upon the closing of the Tectonic private financings in the anticipated aggregate amount of $130.7 million. We note your disclosure to this effect on page 27. Discuss
risks and uncertainties if stockholders are asked to make voting decisions without knowing whether the private financings will close in timely manner, or at all. Discuss the combined company’s liquidity position and related risks in the event
that the merger closes without the private financings in place.

 Response: The Company respectfully
acknowledges the Staff’s comment and advises the Staff that it has revised the disclosure on the cover page and pages 3, 29, 36-37, 228, 234, 259, 327, 391 and 406 of the Amended Registration Statement.

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 Office of Life Sciences

March 25, 2024

  Page
 2

 Why are the two companies proposing to merge?, page 2

3.
 Please revise your disclosure to clarify the combined company’s plans with respect to AVROBIO’s
legacy business. In this regard, we note your disclosure on page 13 and elsewhere throughout that on July 12, 2023, AVROBIO halted development of its clinical and research programs to explore strategic alternatives which may include, but are not
limited to, a divestiture of its legacy business.

 Response: The Company respectfully acknowledges the
Staff’s comment and advises the Staff that, while it is true that it is anticipated that the combined company will not continue to develop the Company’s legacy product candidates, as reflected in the Amended Registration Statement,
Tectonic believes it may have potential uses for certain of the Company’s intellectual property, which it may explore in the future. For example, the Company’s platform uses a proprietary lentiviral-based gene therapy approach for
autologous transduction of human hematopoietic stem cells. Tectonic believes it could potentially use this lentiviral-based technology combined with antibodies/nanobodies discovered using Tectonic’s GEODE platform to develop CAR-T cell
therapies targeting cells overexpressing GPCRs. In addition, Tectonic may choose in the future to further explore the modulation of immune responses in autoimmune diseases using the Company’s proprietary technology. During the 18-month period
following the closing, pursuant to the terms of the CVR Agreement, the combined company will use commercially reasonable efforts (as defined in the CVR Agreement) to effect dispositions of the Company’s pre-closing assets to a third party that
has delivered inbound interest (as defined in the CVR Agreement) with respect to such assets.

 What are contingent value rights (CVRs)?, page 5

4.
 We note that you disclose here and elsewhere that AVROBIO stockholders of record “as of immediately
prior to the effective time” will receive one non-transferable CVR for each outstanding share of AVROBIO common stock held by such stockholder on such date. However, disclosure following the first bullet
on page 190 states that a record date will be agreed to by AVROBIO and Tectonic prior to the effective time, and disclosure on page 237 states that the record date for the CVR distribution will be the “close of business on the business day
immediately prior to the day on which the effective time occurs.” Please revise throughout to reconcile your disclosures and clarify the record date for the issuance of CVRs to AVROBIO stockholders.

Response: The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has revised the disclosure on
pages 20, 195 and 244 of the Amended Registration Statement.

 Will the common stock of the combined company trade on an exchange?, page 7

5.
 You disclose that
AVROBIO intends to file an initial listing
application for the combined company’s common stock with Nasdaq and that it is expected that such common
stock will trade on the exchange. We also
note Section 6.10 of the Merger Agreement
provides that the approval of the listing of the additional shares of AVROBIO’s common stock on Nasdaq shall have been conditionally approved prior to the Effective
Time.

•

 Please revise the Letter to Stockholders, Q&A, and elsewhere throughout as appropriate to clarify that
the closing of the merger is conditioned upon Nasdaq’s approval of the listing application.

•

 Disclose whether this condition is waivable and if so, by which party or parties.

•

 Indicate whether or not Nasdaq’s determination will be known at the time that stockholders are asked
to vote to approve the merger.

•

 Please also include a cross-reference to risk factor disclosure stating that the potential reverse stock
split may not result in an increase in the combined company’s stock price necessary to satisfy Nasdaq’s initial or continued listing requirements for the combined company.

Response: The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has revised the disclosure on the
cover page and pages 7, 33 and 228 of the Amended Registration Statement. The Company further advises the Staff that Nasdaq has not yet made a determination with respect to the approval of the listing of the additional shares of AVROBIO common stock
on Nasdaq, and such approval may not be known at the time that AVROBIO stockholders are asked to vote to approve the merger. Additionally, the Company advises the Staff that this condition to the closing of the merger is waivable but only to the
extent permitted by law and only with the written waiver of each of the Company, Tectonic and Merger Sub.

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 Office of Life Sciences

March 25, 2024

  Page
 3

 What are the material U.S. federal income tax consequences of the merger to U.S. Holders of Tectonic
common stock?, page 11

6.
 We note your representation here and beginning on page 219 that the parties “intend” the merger
to qualify as a reorganization within the meaning of Section 368(a) of the U.S. Internal Revenue Code of 1986, as amended (the “Code”). Please revise your disclosure here and throughout, including the
sections addressing the tax consequences of the CVRs, to provide counsel’s firm opinion for each material tax consequence, including whether the merger will qualify as a reorganization, or to explain why such opinion cannot be given. If the
opinion is subject to uncertainty, please: (1) provide an opinion that reflects the degree of uncertainty (e.g., “should” or “more likely than not”) and explains the facts or circumstances giving
rise to the uncertainty; and (2) provide disclosure of the possible alternative tax consequences including risk factor and/or other appropriate disclosure setting forth the risks of uncertain tax
treatment to investors. Also, please file the tax opinion as an exhibit to the registration statement. Please refer to Item 601(b)(8) of Regulation S-K and Section III.A. of Staff Legal Bulletin 19, Legality
and Tax Opinions in Registered Offerings.

 Response: The Company respectfully acknowledges the
Staff’s comment and advises the Staff that, because the AVROBIO stockholders are not exchanging their shares in the merger, the U.S. federal income tax consequences of the merger are not material to the Company or its shareholders. Regardless
of whether the merger qualifies as a reorganization within the meaning of Section 368(a) of the Code, it will not be a taxable transaction to the AVROBIO stockholders.

Whether or not the merger qualifies as a “reorganization” within the meaning of Section 368(a) of the Code will not impact the
AVROBIO stockholders’ decision to approve or not approve the merger or to purchase or sell the Company’s shares (or, following the consummation of the merger, shares of the combined company). Existing AVROBIO stockholders will not exchange
their shares for shares in any other entity, but will simply retain their existing shares in the Company.

 The only parties affected by the
qualification of the merger as a “reorganization” under Section 368(a) of the Code are Tectonic stockholders. However, the Amended Registration Statement is not soliciting the consent of the Tectonic stockholders to the transactions,
and such stockholders are not voting at the Company’s special meeting. Rather, promptly after the Amended Registration Statement is declared effective under the Securities Act, Tectonic will disseminate to Tectonic stockholders an information
statement that includes a material description of the merger, the Merger Agreement and related ancillary documents and appraisal rights available under Delaware law, for purposes of soliciting such Tectonic stockholders’ consent to adopt the
Merger Agreement and approve the merger. The information statement also will contain information with respect to the qualification of the merger as a “reorganization” within the meaning of Section 368(a) of the Code. In connection
with their consideration of the transaction, and based on their review of the information statement, the Merger Agreement and the ancillary agreements, the Tectonic stockholders can seek advice from their own tax advisors and will be responsible for
paying their own taxes, if any, that result from the merger. The Company and its stockholders are not required to indemnify Tectonic stockholders for such taxes, if any.

Due to substantial uncertainty as to the tax treatment of the receipt of the CVRs and the lack of authority addressing such tax treatment,
Goodwin Procter LLP and Cooley LLP, the tax counsels for the Company and Tectonic, respectively, cannot express an opinion on the tax consequences of the receipt of the CVRs. The tax disclosure in the Amended Registration Statement has been revised
on pages 12 and 264 to highlight this uncertainty and the fact that opinions cannot be provided.

 Prospectus Summary

The Companies

 AVROBIO, page 13

7.
 With reference to your disclosure on pages 13 and 17, please revise the Summary and the Q&A to
highlight, if true, that if the merger is completed, the combined company will focus on developing Tectonic’s product candidates, and it is anticipated that the combined company will not continue to develop AVROBIO’s legacy product
candidates. Also, revise the Q&A on page 5 to provide context for the discussion of the CVRs.

Response: The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has revised the disclosure on
pages 2, 6-7 and 14 of the Amended Registration Statement. The Company further advises the Staff that while it is true that it is anticipated that the combined company will not continue to develop the Company’s legacy product candidates, as
reflected in the Amended Registration Statement, Tectonic believes it may have potential uses for certain of

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 Office of Life Sciences

March 25, 2024

  Page
 4

the Company’s intellectual property. The Company’s platform uses a proprietary lentiviral-based gene therapy approach for autologous transduction of human hematopoietic stem cells.
Tectonic believes it could potentially use this lentiviral-based technology combined with antibodies/nanobodies discovered using Tectonic’s GEODE platform to develop CAR-T cell therapies targeting cells
overexpressing GPCRs. In addition, Tectonic may choose in the future to further explore the modulation of immune responses in autoimmune diseases using the Company’s proprietary technology.

Tectonic, page 14

8.
 Please revise the Summary and Tectonic’s Business section to provide context and balance to the
discussion of Tectonic’s proprietary technology platform, GEODe. To the extent you highlight the capabilities of the platform and Tectonic’s belief that it can “overcome the existing challenges of GPCR-targeted drug discovery”
when engineering product candidates, please also explain that Tectonic has limited experience in therapeutic discovery and development and that the platform may never result in the regulatory approval of a product candidate.

 Response: The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has
revised the disclosure on pages 16 and 352 of the Amended Registration Statement. The Company further advises the Staff that the Company has added a risk factor on page 110 of the Amended Registration Statement in response to the Staff’s
comment.

 Interests of AVROBIO’s Directors and Executive Officers in the Merger, page 20

9.
 Here and in the parallel sections of the registration statement regarding the interests of
Tectonic’s directors and executive officers in the merger, please revise to quantify the value of the interests of such parties. For example only, please disclose on an aggregate basis:

•

 the value of options to purchase AVROBIO common stock that will be subject to accelerated vesting, and the
value of RSUs that will be subject to accelerated vesting and settlement into shares of AVROBIO common stock, including any necessary assumptions; and

•

 the amount of additional cash payments or “golden parachute” compensation to be received in
connection with the merger due to change in control agreements, employment contract terminations, consulting fees, etc.

Response: The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has revised the disclosure on
pages 22-23 and 217 of the Amended Registration Statement.

10.
 Here and elsewhere as appropriate, please revise to explain whether any material payments to
AVROBIO’s executives, such as “golden parachute” compensation that