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July 7, 2023
Jordan Licht
Chief Financial Officer
Burford Capital Limited
Oak House
Hirzel Street
St. Peter Port GY1 2NP
Guernsey
Re:Burford Capital Limited
Forms 20-F for the Fiscal Years Ended December 31, 2021 and 2022
Filed March 29, 2022 and May 16, 2023, respectively
Form 6-K dated June 13, 2023
Filed June 13, 2023
File No. 001-39511
Dear Jordan Licht:
            We have reviewed your January 26, 2023 and April 25, 2023 responses to our comment
letter and the filings referenced above 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.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
January 12, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Financial and operational review
Economic and market conditions
Inflation, page 27
1.Please tell us your consideration for disclosing the impact of higher interest rates
associated with inflation on the fair value of your capital provision assets and related

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Burford Capital Limited
July 7, 2023
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unrealized gains or losses.
Results of operations and financial position
Statement of operations for the year ended December 31, 2022 compared to the year ended
December 31, 2021
Capital provision income, page 29
2.Please provide us proposed revised disclosure to be included in future filings that provides
a more robust and quantified explanation for the increase in your consolidated capital
provision income from $194.6 million in 2021 to $319.1 million in 2022, consistent with
the requirements in Item 303(b)(2) of Regulation S-K.  In your proposed revised
disclosure, at a minimum, address the following:
•Quantify the "higher volume of favorable case resolutions, which drove higher
realized gains" in terms of number of cases and the realized gains.  In this regard,
from the tables on page 30 and Note 6 on page 109, realized gains relative to cost
only contributed $8.1, or 6.5%, of the $124.6 million increase in capital provision
income.
•Explain why the "higher volume of favorable case resolutions" resulted in slightly
higher realized gains when it is apparent from disclosure in the tables at the bottom of
page 59 and in Note 7 on page 109 that overall consolidated realizations declined
from $455.1 million in 2021 to $426.7 million in 2022.
•Quantify separately the number of cases with positive case milestones achieved and
negative case milestones suffered during the year and the impact of each on your fair
value adjustment during the year.  In this regard and notwithstanding your Chief
Executive Officer's (CEO) statement of intent in your June 13, 2023 earnings
conference call to not provide case milestone information in the future we note, for
example, discussion of the number of case milestones achieved in the first quarter of
2023 by your Chief Investment Officer during your May 16, 2023 conference call on
Full-Year 2022 Results.  Also in this regard, we note your CEO's statement from your
May 16, 2023 conference call that the largest driver of value in your business is court
decisions and that they will remain the key driver of your valuations. In addition,
discuss any individually significant fair value gains or losses and any trends over
time.
•Quantify the impact of changes in market interest rates and the resulting changes in
your discount rate included in your fair value adjustment.  In this regard, for example,
we note your discussion related to slide 12 in the presentation slide deck
accompanying your May 16, 2023 conference call where you indicate that the
increase in discount rates over the last four years resulted in about $400 million in
foregone income from your portfolio.
•Quantify and discuss the impact of any other material items impacting capital
provision income.

 FirstName LastNameJordan  Licht
 Comapany NameBurford Capital Limited
 July 7, 2023 Page 3
 FirstName LastName
Jordan  Licht
Burford Capital Limited
July 7, 2023
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Portfolio
Overview, page 44
3.Please tell us why it is appropriate to characterize your undrawn commitments as assets in
the tables on pages 45 and 46.  In this regard, please tell us your consideration for revising
in future filings the captions of total capital provision-direct assets and total capital
provision-indirect assets as we note that undrawn commitments do not qualify for asset
recognition under GAAP.  In addition, consider reconciling this disclosure to capital
provision assets on your balance sheet and clearly identifying the columns in this table
and other tables that provide Burford-only, other funds, BOF-C and Group-wide
information as being non-GAAP consistent with your indication on page 7. Please provide
us any proposed changes to be included in future filings.
4.Your tables on pages 45 and 46 as well as those on page 48 in your fair value of capital
provision assets disclosure have captions labeled carrying value.  As you carry your
capital provision assets at fair value, please tell us your consideration for clarifying in the
tables that carrying value is fair value. Provide us any proposed revised disclosure to be
included in future filings.
Undrawn commitments, page 51
5.In the second paragraph in this section you disclose that your consolidated undrawn
commitments were $1.9 billion, $1.7 billion and $1.6 billion at December 31, 2022, 2021
and 2020, respectively.  As these amounts appear to refer to your group-wide totals in the
tables at the bottom of page 51 and not the consolidated totals presented in the table in
Note 21 on page 128, please represent to us that in future filings you will properly identify
the amounts in your narrative disclosure.
Summary of capital provision-direct portfolio, page 55
6.We note the table provided on page 48 of your report for the first quarter of 2023 provided
as Exhibit 99.1 to your Form 6-K filed on June 13, 2023 where you provide a table with
deployed costs and realized proceeds by vintage.  Please tell us your consideration for
augmenting your interim vintage information with information about the status and
number of assets underlying the current period activity so that investors may have a better
understanding of the progress in your portfolio, similar to your presentation on page 55.
Provide us any proposed revised disclosure to be included in future filings.
Critical accounting estimates
Fair value of capital provision assets, page 61
7.We note that the sensitivity analysis provided in this disclosure is the same as the
sensitivity analysis provided in your Fair Value footnote on page 110.  In light of the fact
that you disclose that the estimate of fair value is largely based on management’s estimate
of forecasted cash flows, please tell us the extent to which you considered providing a

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 Comapany NameBurford Capital Limited
 July 7, 2023 Page 4
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Jordan  Licht
Burford Capital Limited
July 7, 2023
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sensitivity of a 10 percent increase or decrease in the most likely expected entitlement
assumption of your capital provision asset, which you refer to as your win node in your
May 16, 2023 Investor Presentation available on your website.  Similarly, in light of the
significant range between the minimum and maximum difference of the duration
unobservable input assumption, please tell us whether you considered providing a
sensitivity of that assumption to show how a change in that assumption could impact your
results. Provide us any proposed revised disclosure to be included in future filings.
Consolidated statements of operations, page 85
8.In your financial and operational review disclosure on page 31 you indicate that your
case-related expenditures ineligible for inclusion in asset cost includes situations where
you are the claimant in a litigation matter, either due to the acquisition of assets, or the
assignment of a claim.  Please address the following:
•Quantity how much of this expense relates to matters you acquired or that were
assigned to you for all periods presented.
•Tell us the process by which you become the claimant in a litigation matter,
separately for the acquisition of assets and the assignment of claims.
•Quantity the number of litigation matters where you are the claimant and explain how
these litigation matters are disclosed in your filing, from the time of acquisition until
the time of resolution.
•Provide an illustrative example of the accounting applied from the
acquisition/assignment of a claim to you, until resolution of the claim, including the
line items in the financial statements where the activity is recorded.
•As you no longer apply a “cost plus” methodology for the recognition of capital
provision assets, tell us your consideration for renaming this expense to remove the
reference to cost.
•Provide us proposed revised disclosure to be provided in future filings that more
clearly describes the nature of these expenses.
Notes to the consolidated financial statements
Note 7. Due from settlement of capital provision assets, page 109
9.We note your $11.3 million unrealized loss in 2022 and your disclosure in Financial and
operating review on page 38 that it relates to an $86.3 million receivable in your Strategic
Value Fund.  Please tell us:
•The nature of this loss;
•How you determined its amount; and
•Why you consider it an unrealized loss when it presumably resulted from a realized
gain when you reclassified it from capital provision assets to due from settlement of
capital provision assets.

 FirstName LastNameJordan  Licht
 Comapany NameBurford Capital Limited
 July 7, 2023 Page 5
 FirstName LastName
Jordan  Licht
Burford Capital Limited
July 7, 2023
Page 5
Note 15. Fair value of assets and liabilities
Valuation methodology, page 115
10.On page 116, you disclose that you have elected the fair value option for certain equity
method investments, marketable securities, due from settlement of capital provision assets
and financial liabilities relating to third-party interests in capital provision assets.  We also
note your disclosure that “there were no gains or losses recognized in the consolidated
statements of operations with respect to these assets and liabilities.”  Please tell us, and
provide us proposed revised disclosure to be included in future filings that clarifies, why
no gains and losses were recorded for each group of assets and liabilities for any of the
reported periods.  Additionally, as part of your response, please clarify whether the
amounts for these assets and liabilities reported in the “Income for the period” columns on
pages 117 and 118 solely represent interest and dividend income.
Movements in Level 3 fair value assets and liabilities, page 117
11.We note that the balances and activity for your total capital provision assets and for your
due from settlement of capital provision assets do not necessarily agree with comparable
balances and activity presented in the separate rollforwards presented in Note 6 for the
former and Note 7 for the latter.  Please tell us why the following amounts differ between
the relevant rollforwards and reconcile for us the following differences:
•The opening balance for capital provision assets at January 1, 2020;
•The realization and income for the period amounts for capital provision assets during
2020;
•The deployments, income for the period and foreign exchange amounts for capital
provision assets during 2022;
•The ending balance for capital provision assets at December 31, 2022;
•The opening balance for due from settlement of capital provision assets at January 1,
2020;
•The deployments and realizations amounts from Note 15 and the relevant captions in
Note 7 for due from settlement of capital provision assets during 2020; and
•The deployments and realizations amounts from Note 15 and the relevant captions in
Note 7 for due from settlement of capital provision assets during 2022.
Sensitivity of Level 3 valuations, page 118
12.In the second paragraph in this section, you disclose that for cases where cash flows are
denominated in a foreign currency, forecasts are developed in the applicable foreign
currency and translated to US dollars.  We note your disclosure from Note 6 on page 109
that exchange differences arising from non-US dollar-denominated capital provision
assets held by US dollar functional currency entities are recognized in capital provision
income while all other foreign exchange translation differences arising from capital
provision assets held by non-US dollar functional currency entities are recognized in other
comprehensive income. Please tell us why your disclosure regarding forecasts in foreign

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 Comapany NameBurford Capital Limited
 July 7, 2023 Page 6
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Burford Capital Limited
July 7, 2023
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currencies is limited to the translation into US dollars instead of translation into the
functional currency of your relevant subsidiary/operations.  In this regard, we note your
disclosure on page 100 that certain subsidiaries operate and prepare financial statements
denominated in pound sterling and euro. In your response, reference, where appropriate,
the authoritative literature you rely upon to support your accounting and address the
following:
•Clarify whether subsidiaries with functional currencies other than the US dollar hold
capital provision assets denominated in currencies other than their functional
currencies.  If so, clarify if changes in the exchange rates between the functional
currency and the contract currency are included in your operating results;
•Explain why the foreign exchange loss for 2022 in the capital provision asset
rollforward in Note 6 on page 108 of $13.1 million differs from the $11.2 million
amount as disclosed in Note 15 on page 117; and
•Clarify whether the difference between the $13.1 million foreign exchange loss
presented in 2022 in the rollforward in Note 6 and the $6.4 million foreign exchange
loss in the components of your capital provision income table on page 109 represents
translation of non-US dollar-denominated functional entity capital provision assets
and related activity into the US dollar reporting currency and is included in other
comprehensive income.
13.In the second paragraph on page 119, you disclose that your fair value policy provides for
ranges of percentages to be applied against the risk adjustment factor to more than 70
discrete objective litigation events (or adjudicative events) across five principal different
types of litigation.  However, in your January 26, 2023 response to the fourth bullet of
prior comment 4 from our January 12, 2023 letter you indicated that during 2022, you
applied a fixed percentage. Please tell us, and provide us proposed revised disclosure to be
included in future filings as appropriate, to address the following:
•Which periods you apply a fixed percentage for each discrete adjudicative event and
which periods you applied a range of percentages.
•For all periods where a range is applied, how you determined what percentage within
each adjudicative event to apply on each asset.
14.Your tables on pages 119 and 120 present positive case and negative case milestone factor
ranges for various aggregated capital provision assets that in total represent more than
65% of total assets as of December 31, 2022 and 2021. Given that the fair value
infor