SecProbe.io

May 7, 2019
Lee Kalowski
Chief Financial Officer
Bicycle Therapeutics Ltd.
4 Hartwell Place
Lexington, Massachusetts 02421
Re:Bicycle Therapeutics Ltd.
Registration Statement on Form S-1
Filed April 26, 2019
CIK 0001761612
Dear Mr. Kalowski:
            We have reviewed your registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form S-1 filed on April 26, 2019
Description of American Depositary Shares, page 212
1.We note the revised disclosure regarding the waiver of jury trial provision in page 223 of
your registration statement.  Please further revise your disclosure to address any questions
as to enforceability of such waiver and to state that, by agreeing to the terms of the deposit
agreement, investors will not be deemed to have waived our or the depositary's
compliance with U.S. federal securities laws and the rules and regulations promulgated
thereunder.
            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.

 FirstName LastNameLee Kalowski
 Comapany NameBicycle Therapeutics Ltd.
 May 7, 2019 Page 2
 FirstName LastName
Lee Kalowski
Bicycle Therapeutics Ltd.
May 7, 2019
Page 2
            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.
            You may contact Jim Dunn at 202-551-3724 or Isaac Esquivel at 202-551-3395 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Liz Walsh at 202-551-3696 or Christopher Edwards at 202-551-6761 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance
cc:       Jonathan Schur