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CORRESP
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CORRESP

 October 11, 2024

VIA EDGAR

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street,
N.E.

 Washington, D.C. 20549

 Attention: Frank Wyman, Daniel
Gordon

Re:
 PureTech Health plc

Form 20-F for the fiscal year ended December 31, 2023

Filed April 25, 2024

 File No. 001-39670

 Dear Mr. Wyman and Mr. Gordon:

On behalf of PureTech Health plc (the “Group,” “we,” or “our”), I am submitting this letter in response to
comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received by letter dated September 17, 2024, concerning the Group’s Form 20-F
for the fiscal year ended December 31, 2023, filed with the Commission on April 25, 2024.

 To assist your review, the text of
the Staff’s comments is presented in italics below.

 Form 20-F for the fiscal year ended December 31,
2023

 Notes to Consolidated Financial Statements

Note 5. Investments at Fair Value, page F-22

1.
 In 2023, you recognized a $61.7 million gain upon deconsolidation of Vedanta and a $27.2 gain upon
deconsolidation of Sonde in 2022. Please provide an analysis supporting these loss-of-control conclusions, including your consideration of Vedanta’s issuance of
convertible debt and Sonde’s issuance of Series B preferred shares. Also, provide detailed calculations supporting these deconsolidation gains, including key assumptions used to determine fair value of your retained investment and a description
and quantification of specific assets and liabilities for Vedanta and Sonde prior to their deconsolidation. In this regard, explain how you identified and valued assets and liabilities to be deconsolidated with Vedanta and Sonde, and describe assets
or liabilities associated with these entities that remained in your consolidation (as applicable). Refer us to the technical guidance upon which you relied. In addition, explain the impact on your ongoing assessments of “power to control”
and “significant influence” from contractual arrangements and financing arrangements with these Founded Entities following their deconsolidation. Revise your disclosure accordingly.

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 Response: As disclosed in Note 1, Material Accounting Policies, (Note 1), to our
consolidated financial statements, if the power to control the investee exists, the Group consolidates the financial statements of the investee into its consolidated financial statements. We include the following disclosure in Note 1:

The Group considers among others its voting shares, shareholder agreements, ability to appoint board members, representation on the board, rights to appoint
management, de facto control, investee dependence on the Group, etc. If the power to control the investee exists, it consolidates the financial statements of such investee in the Consolidated Financial Statements of the Group. Upon issuance of new
shares in an investee and/or a change in any shareholders or governance agreements, the Group reassesses its ability to control the investee based on the revised voting interest, revised board composition and revised subsidiary governance and
management structure. When such new circumstances result in the Group losing its power to control the investee, the investee is deconsolidated.

 We
acknowledge the Staff’s comment and note that there are several sub-questions embedded within this particular comment from the Staff on our deconsolidation of Vedanta Biosciences, Inc. (Vedanta) in 2023
and Sonde Health, Inc. (Sonde) in 2022. For the sake of clarity, we respectfully advise the Staff that we have responded below to each sub-question separately for each deconsolidation.

Vedanta Biosciences, Inc (Vedanta)

a)
 Please provide an analysis supporting these loss-of-control conclusions, including your consideration of Vedanta’s issuance of convertible debt.

In accordance with International Financial Reporting Standards (IFRS) 10, Consolidated Financial Statements, (IFRS 10), paragraph 7, an
investor controls an investee if and only if the investor has all of the following: (a) power over the investee, (b) exposure or rights to variable returns from its involvement with the investee, and (c) the ability to use its power
over the investee to affect the amount of the investor’s returns.

 Paragraph 10 of IFRS states that an investor has power over an
investee when the investor has existing rights that give it the current ability to direct the relevant activities, i.e. the activities that significantly affect the investee’s returns. In accordance with paragraph B3 of IFRS 10, the Group
considered the purpose and design of the investee to identify, (a) what the relevant activities are, (b) how decisions about those activities are made, (c) who has the current ability to direct the relevant activities and (d) who
receives the returns from those activities.

 Vedanta is a clinical stage biopharmaceutical company pioneering the development of oral
therapies that modulate the human microbiome to treat disease. The relevant activities of Vedanta include performing research and development to advance its scientific programs which include, among others, product candidates for C. difficle
infection and inflammatory bowel disease, making decisions about whether to move forward with the development of a

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scientific or clinical program, as well as obtaining funding to advance its programs. The key decisions about the relevant activities are made by Vedanta’s Board of Directors with each board
member having one vote. As a majority vote is required for a decision to be made on the relevant activities, an investor would need to therefore control the majority of the board of directors in order to control Vedanta’s relevant activities.
The composition of Vedanta’s Board of Directors is determined by Vedanta’s Amended and Restated Investor Rights Agreement dated March 1, 2023 by and among Vedanta Biosciences, Inc and the investors and noteholders party thereto (the
Investor Rights Agreement.)

 As of December 31, 2022, the Group controlled six out of eight seats on Vedanta’s Board of Directors
which gave it the power to direct Vedanta’s relevant activities. As disclosed in Note 5, Investments Held at Fair Value, Vedanta issued convertible debt to a syndicate of investors on March 1, 2023, and amended its Investor Rights
Agreement to grant the convertible debt holders representation on Vedanta’s Board of Directors. This change in the Investor Rights Agreement and the composition of the Vedanta Board of Directors resulted in the Group losing control of the
Vedanta Board of Directors. As of March 1, 2023, the Group held two out of nine seats on Vedanta’s Board of Directors and could appoint two additional individuals to the Vedanta Board of Directors. Therefore, the Group’s maximum
representation on the Vedanta Board of Directors could be four out of eleven board seats.

 On March 1, 2023, we concluded that the
Group no longer had the power to direct the relevant Vedanta activities because the relevant activities of Vedanta are directed by Vedanta’s Board, and the Group no longer controls the Vedanta Board of Directors.

To further support our conclusion that we no longer had the power to direct the relevant Vedanta activities as of March 1, 2023, we
performed the following assessment at the time of deconsolidation:

•

 We considered the guidance in paragraph B14 and B15 of IFRS 10, which states that to have power over an investee,
an investor must have existing rights that give the investor the current ability to direct the relevant activities. Examples of rights that, either individually, or in combination, can give an investor power include, but are not limited to
(a) rights in the form of voting rights, (b) rights to appoint, reassign or remove members of an investee’s key management personnel who have the ability to direct the relevant activities; (c) rights to appoint or remove another
entity that directs the relevant activities; (d) rights to direct the investee to enter into, or veto any changes to, transactions for the benefit of the investor, and other rights (such as decision-making rights specified in a management
contract) that give the holder the ability to direct the relevant activities. The key decisions on the relevant Vedanta activities are made by the Vedanta Board of Directors. Our voting rights are not sufficient to provide us with the power to
direct the relevant activities as we do not control the Vedanta Board of Directors. We also do not have the ability to unilaterally appoint, reassign or remove members of Vedanta management or any individuals who comprise the Board of Directors. We
cannot solely direct Vedanta to enter into, or veto, any changes to transactions for our benefit and there are no contractual agreements that provide us with decision making rights that give us the ability to direct the relevant activities of
Vedanta.

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•

 We also considered the guidance in paragraph B38 of IFRS 10 which states that an investor can have power even if
it holds less than a majority of the voting rights of an investee. An investor can have power with less than a majority of the voting rights of an investee through: (a) a contractual arrangement between the investor and other vote holders,
(b) rights arising from other contractual arrangements, (c) the investor’s voting rights, (d) potential voting rights, or (e) a combination of (a)-(d). We do not have any contractual agreements that enable us to control
sufficient votes held by other investors to provide us with power over the relevant Vedanta activities. There are no contractual agreements that provide us with decision making rights that give us the ability to direct the relevant Vedanta
activities. For example, Vedanta has its own arrangements in place to perform research and development activities on its scientific programs and does not use the Group to perform any of its research and development activities. Our voting rights are
not sufficient to provide us with power to unilaterally direct the relevant activities as we do not have control of the Vedanta Board of Directors. We also do not hold any substantive potential voting rights and there is no combination of voting
rights and potential voting rights that provide us with control of the Vedanta Board of Directors or the power to direct the relevant activities of Vedanta as of March 1, 2023.

•

 Finally, we considered whether we have de-facto control as defined in the
IFRS literature, which refers to when an investor has power over an investee, even if the investor does not own a majority of the shares. This can occur when an investor has the ability to direct the investee’s activities even if the investor
has less than 50% of the voting shares. We concluded that we do not have de-facto control of Vedanta as the Investor Rights Agreement stipulates that the relevant activities of Vedanta are directed by
Vedanta’s Board of Directors which we do not control. In Note 1 to our consolidated financial statements, on Page F-11, we disclosed our evaluation and conclusion of
de-facto control related to Vedanta.

 Based on our overall assessment of all the
relevant facts, we concluded that we do not have the power to direct the relevant activities at Vedanta as of March 1, 2023. Therefore, we deconsolidated Vedanta from our consolidated financial statements on March 1, 2023.

b)
 Also, provide detailed calculations supporting the Vedanta deconsolidation gain of $61.7 million,
including key assumptions used to determine fair value of your retained investment and a description and quantification of specific assets and liabilities for Vedanta prior to the deconsolidation. In this regard, explain how you identified and
valued assets and liabilities to be deconsolidated with Vedanta, and describe assets or liabilities associated with Vedanta that remained in your consolidation (as applicable). Refer us to the technical guidance upon which you relied.

 In accordance with paragraph B98 of IFRS 10, when the Group lost control of Vedanta, the Group derecognized the
assets and liabilities of Vedanta at their carrying amounts (B98(a)(i)) and derecognized the carrying amount of non-controlling interest at the date when control is lost (B98(a)(ii)). The Group also recognized
the investment it retained in Vedanta at fair value when control is lost (B98(b)(iii)) and recognized any resulting difference as a gain or loss (B98(d)).

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 The events that caused the Group to lose control of Vedanta did not result in the Group
receiving any consideration (B98(b)(i)) nor involve a distribution of shares of Vedanta to owners (B98(b)(ii)). Also, there were no amounts previously recognized in other comprehensive income in relation to Vedanta (B98(c)).

A detailed calculation supporting the gain recognized on the deconsolidation of Vedanta, including a description and quantification of the
specific assets and liabilities of Vedanta, which is consistent with the information disclosed on page F-10 of our Form 20-F, is provided in the table below.

 IFRS 10
guidance

$000s

$000s

 B98(a)(i)

Derecognize total assets and liabilities of the subsidiary at their carrying amounts at the date when control was lost:

Cash and cash equivalents

(13,784
)

Trade and other receivables

(702
)

Prepaid assets

(3,516
)

Property, plant and equipment, net

(8,092
)

Right of use asset, net

(2,477
)

Trade and other payables

15,078

Deferred revenue

1,902

Lease liabilities (including current portion)

4,146

Long-term loan (including current portion)

15,446

Subsidiary preferred shares

24,568

Other assets and liabilities, net

(323
)

Sub-total (net liabilities)

32,246

 B98(a)(ii)

Derecognize the carrying amount of non-controlling interest

9,085

 B98(b)(iii)

Recognize at fair value the investment retained in Vedanta convertible preferred shares

20,456

 B98(d)

Gain on deconsolidation of Vedanta

61,787

 The specific assets and liabilities for Vedanta prior to the deconsolidation are included in the table above.
Prior to deconsolidation, we maintained a separate ledger in our accounting and financial reporting system that contained the assets and liabilities of Vedanta. As a result, the process of identifying the assets and liabilities to be deconsolidated,
as of the date of deconsolidation, was straightforward and involved limited judgment.

 5

 On the date of deconsolidation, the Group derecognized the assets and liabilities of Vedanta
at their carrying amounts except for the subsidiary preferred share liability, which represents shares of Vedanta’s convertible preferred stock issued to third parties. The subsidiary preferred share liability is recognized at fair value in
accordance with IFRS 9, Financial Instruments and was remeasured prior to deconsolidation.

 To assist us in the determination of the
fair value of the subsidiary preferred share liability and our retained investment in Vedanta’s convertible preferred shares, we engaged an independent third-party valuation firm. The valuation method and assumptions used to determine the fair
value of the subsidiary preferred share liability and our retained investment in Vedanta’s convertible preferred shares is similar as both the subsidiary preferred share liability and our investment in Vedanta’s convertible preferred
shares represent investments in Vedanta’s convertible preferred stock. The methodology used to determine the fair value was a market back solve methodology that leveraged a Monte Carlo simulation utilizing significant unobservable inputs,
including the equity value of Vedanta, assumed time to liquidity, and assumed volatility. As the assumptions used and related sensitivities are substantially similar on both the date of deconsolidation and December 31, 2023, we disclosed these
significant assumptions and the sensitivity range for each assumption in Note 18, Financial Instruments, on Page F-42 o