SecProbe.io

December 15, 2017
David A. Giljohann, Ph.D.
Chief Executive Officer
Exicure, Inc.
8045 Lamon Avenue, Suite 410
Skokie, IL 60077
Re:Exicure, Inc.
Registration Statement on Form S-1
Filed November 28, 2017
File No. 333-221791
Dear Dr. Giljohann:
            We have limited our review of your registration statement to those issues we have
addressed in our comment.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to the comment, we may have additional comments.
Registration Statement on Form S-1
General
1.Please provide us your analysis as to why each of the selling shareholders who received
your shares in the Merger or Private Placement should not be deemed underwriters
pursuant to Securities Act Rule 145(c). To the extent they are, please name them as
underwriters and revise to clarify that the price at which they are offering their shares
will remain fixed for the duration of the offering. If they are not, please provide us a basis
for your conclusion, including a discussion of whether such selling shareholders were a
party to or an affiliate of a party to the business combination transaction discussed in
this prospectus. Refer to Section II.G of Securities Act Release 33-8869 (2007).

 FirstName LastNameDavid A. Giljohann, Ph.D.
 Comapany NameExicure, Inc.
 June 16, 2017 Page 2
 FirstName LastName
David A. Giljohann, Ph.D.
Exicure, Inc.
December 15, 2017
Page 2
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Chris Edwards at (202) 551-6761 or Suzanne Hayes at (202) 551-3675
with any questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Sam Zucker