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Correspondence 0001104659-24-100172 from Zura Bio Ltd (ZURA)

Zura Bio Ltd
Date: Sept. 16, 2024 · CIK: 0001855644 · Accession: 0001104659-24-100172

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File numbers found in text: 333-281905

Date
September 16, 2024
Author
ZURA BIO LIMITED
Form
CORRESP
Company
Zura Bio Ltd

Letter

Zura Bio Limited

1489 W. Warm Springs Rd. #110

Henderson, NV 89014

September 16, 2024

VIA EDGAR

Division of Corporation Finance

Office of Technology

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

RE: Zura Bio Limited

Registration Statement on Form S-3

File No. 333-281905

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Exchange Act of 1933, as amended, Zura Bio Limited (the “Registrant”) hereby requests that the U.S. Securities and Exchange Commission (the “Commission”) take appropriate action to cause the above-referenced Registration Statement on Form S-3 to become effective on September 17, 2024, at 9:00 a.m., Eastern Time, or as soon thereafter as is practicable or at such later time as the Registrant may orally request via telephone call to the staff of the Commission. The Registrant hereby authorizes each of Divakar Gupta, Sarah Sellers and Brandon Fenn of Cooley LLP, counsel to the Registrant, to make such request on its behalf.

Once the Registration Statement has been declared effective, please orally confirm that event with Sarah Sellers of Cooley LLP, counsel to the Registrant, at (212) 479-6370, or in her absence, Brandon Fenn at (212) 479-6626.

Very truly yours,
ZURA BIO LIMITED

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CORRESP
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Zura Bio Limited

1489 W. Warm Springs Rd. #110

Henderson, NV 89014

September 16, 2024

VIA EDGAR

Division of Corporation Finance

Office of Technology

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

  RE:
  Zura Bio Limited

  Registration Statement on Form S-3

  File No. 333-281905

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Exchange
Act of 1933, as amended, Zura Bio Limited (the “Registrant”) hereby requests that the U.S. Securities and Exchange
Commission (the “Commission”) take appropriate action to cause the above-referenced Registration Statement on Form S-3 to
become effective on September 17, 2024, at 9:00 a.m., Eastern Time, or as soon thereafter as is practicable or at such later time as the
Registrant may orally request via telephone call to the staff of the Commission. The Registrant hereby authorizes each of Divakar Gupta,
Sarah Sellers and Brandon Fenn of Cooley LLP, counsel to the Registrant, to make such request on its behalf.

Once the Registration Statement has been declared
effective, please orally confirm that event with Sarah Sellers of Cooley LLP, counsel to the Registrant, at (212) 479-6370, or in
her absence, Brandon Fenn at (212) 479-6626.

    Very truly yours,

    ZURA BIO LIMITED

    By:
    /s/ Verender Badial

    Name:
    Verender Badial

    Title:
    Chief Financial Officer

  cc:
  Kim Davis, Zura Bio Limited

  Divakar Gupta, Cooley LLP

  Sarah Sellers, Cooley LLP

  Brandon Fenn, Cooley LLP