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CORRESP
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    One Financial Center

    Boston, MA 02111

    617 542 6000

    mintz.com

CERTAIN PORTIONS OF THIS LETTER AS FILED VIA
EDGAR HAVE BEEN OMITTED AND FILED SEPARATELY WITH THE COMMISSION. CONFIDENTIAL TREATMENT HAS BEEN REQUESTED FOR THE OMITTED PORTIONS,
WHICH HAVE BEEN REPLACED WITH THE PLACEHOLDER “[***].”

January 11, 2024

VIA
EDGAR AND COURIER

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Christopher Edwards and Suzanne
Hayes, Office of Life Sciences

 Re: ArriVent Biopharma, Inc.

Draft Registration Statement on Form S-1

Originally submitted August 25, 2023

Registration Statement on Form S-1 (Reg. No. 333-276397)

Filed January 5, 2024

CIK No. 0001868279

Ladies and Gentlemen:

On
behalf of ArriVent Biopharma, Inc.(the “Company”), in response to comments from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) received by letter dated September 27, 2023
(the “Comment Letter”) relating to the Company’s Draft Registration Statement on Form S-1, originally
confidentially submitted to the Commission on August 25, 2023, resubmitted to the Commission on October 4, 2023, October 31,
2023, and December 5, 2023 and publicly filed with the Commission on January 5, 2024 (Reg. No. 333-276397) (the
 “Registration Statement”), we submit this supplemental letter to address Comment 15 of the Comment Letter.

Because of the commercially sensitive nature of
the information contained herein, this submission is accompanied by the Company’s request for confidential treatment for selected
portions of this letter. The Company has filed a separate letter with the Office of Freedom of Information and Privacy Act Operations
in connection with the confidential treatment request, pursuant to Rule 83 of the Commission’s Rules on Information and
Requests, 17 C.F.R. § 200.83. For the Staff’s reference, we have enclosed a copy of the Company’s letter to the Office
of Freedom of Information and Privacy Act Operations, as well as a copy of this correspondence, marked to show the portions redacted from
the version filed via EDGAR and for which the Company is requesting confidential treatment.

The supplemental response set forth below is based
on information provided to Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C. by representatives of the Company. For the convenience
of the Staff, we have recited the prior comment from the Staff in italicized type and have followed the comment with the Company’s
response. All capitalized terms not otherwise defined herein have the meanings ascribed to them in the Registration Statement.

Boston      Los Angeles      New York      San Diego      San Francisco      toronto       Washington

MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C.

FOIA CONFIDENTIAL TREATMENT REQUESTED PURSUANT TO 17 C.F.R. § 200.83

BY ARRIVENT BIOPHARMA, INC.
 IN CONNECTION WITH REGISTRATION STATEMENT ON FORM S-1 (FILE NO. 333-276397)

    MINTZ

 January 11, 2024
 Page 2

 15. Once you have an estimated offering price or range, please explain to us how you determined the fair value of the common stock
underlying your equity issuances and the reasons for any differences between the recent valuations of your common stock leading up to
the initial public offering and the estimated offering price. This information will help facilitate our review of your accounting for
equity issuances, including stock compensation. Please discuss with the staff how to submit your response.

The Company respectfully submits the below additional
information to assist the Staff in its review of the Company’s position with respect to its determination of the fair value of its
common stock underlying its outstanding option awards and the reasons for the differences between the recent valuations of its common
stock and the estimated offering price for its initial public offering (“IPO”).

Preliminary IPO Price Range

The Company advises the Staff that it preliminarily
estimates a price range of approximately $[***] to $[***] per share for its IPO, which does not reflect an expected [***]-for-[***] reverse
stock split of the Company’s capital stock that the Company plans to implement prior to the effectiveness of the Registration Statement
(the “Preliminary Price Range”). The actual price range to be included in a subsequent amendment to the Registration
Statement (which will comply with the Staff’s interpretation regarding the parameters of a bona fide price range) has not
yet been determined and remains subject to adjustment based on factors outside of the Company’s control. However, the Company believes
that the foregoing indicative price range will not be subject to significant change. The share and per-share numbers in this letter are
presented on a pre-split basis.

As is typical in IPOs, the Preliminary Price Range
was not derived using a formal determination of fair value, but was determined based on discussions between the Company and the underwriters.
Among the factors that were considered in setting the Preliminary Price Range were (i) the general conditions of the capital markets
and the recent market prices of, and the demand for, publicly traded common stock of comparable companies in the life sciences sector;
(ii) the Company’s financial condition and prospects; (iii) estimates of business potential and earnings prospects for
the Company and the industry in which it operates; (iv) recent performance of IPOs of comparable companies in the life sciences sector;
and (v) the development and progress of the Company’s lead product candidate, furmonertinib, and other pipeline development
programs.

Common Stock Valuation Methodologies

As
there has been no public market for the Company’s common stock to date, the estimated fair value of its common stock has been
determined by the Company’s board of directors (the “Board”) as of the date of each option grant,
with input from management, and taking into consideration the most recent analysis conducted by a third-party valuation firm
to assist with estimation of fair value of the Company’s common stock, as well as the Board’s assessment of additional
objective and subjective factors (including those listed on page 108 and 109 of the Registration Statement) that it believed
were relevant at such time. There are significant judgments and estimates inherent in the Board’s determination of the fair value
of the Company’s common stock. The judgments and estimates have taken into account numerous factors, including but not limited
to, contemporaneous valuations of the Company’s common stock, the Company’s business, financial condition and results of
operations, and related industry trends affecting its operations; the likelihood of achieving a liquidity event, such as an initial
public offering or a sale, given prevailing market conditions; the lack of marketability of the Company’s common stock as a
private company; the market performance of comparable publicly traded companies in the life sciences and biopharmaceutical industry
sectors; and U.S. and global economic and capital market conditions.

Boston      Los Angeles      New York      San Diego      San Francisco      toronto       Washington

MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C.

FOIA CONFIDENTIAL TREATMENT REQUESTED PURSUANT TO 17 C.F.R. § 200.83

BY ARRIVENT BIOPHARMA, INC.
 IN CONNECTION WITH REGISTRATION STATEMENT ON FORM S-1 (FILE NO. 333-276397)

    MINTZ

 January 11, 2024
 Page 3

The third-party valuations of the Company’s
common stock that the Board considered in making its determinations were prepared in accordance with the American Institute of Certified
Public Accountants’ Accounting and Valuation Guide, Valuation of Privately-Held-Company Equity Securities Issued as Compensation
(the “Practice Guide”), which prescribes several valuation approaches for determining the value of an enterprise,
such as the cost, market and income approaches, and various methodologies for allocating the value of an enterprise to its capital structure
and specifically the common stock.

In accordance with the Practice Guide, the Company
considered the following methods for allocating the enterprise value across its classes and series of capital stock to determine the estimated
fair value of its common stock at each valuation date.

 • Option Pricing Method (“OPM”). The OPM estimates the value of the common equity of the Company using the
various inputs in the Black-Scholes option pricing model. The OPM treats the rights of the holders of common stock as equivalent to that
of call options on any value of the enterprise above certain break points of value based upon the liquidation preferences of the holders
of the Company’s convertible preferred stock, as well as their rights to participation. Thus, the value of the common stock can
be determined by estimating the value of its portion of each of these call option rights. Under this method, the common stock has value
only if the funds available for distribution to the common stockholders exceed the value of the liquidation preferences of the preferred
stockholders at the time of a liquidity event, such as a merger or sale. Given that the common stock represents a non-marketable equity
interest in a private enterprise, an adjustment to the preliminary value estimates is made to account for the lack of liquidity that a
stockholder experiences. This adjustment is commonly referred to as a discount for lack of marketability (“DLOM”).

 • Current Value Method (“CVM”). This method is based on first determining enterprise value using one or more
of the three valuation approaches (market, income or asset-based), then allocating the value to the various series of preferred and common
stock based on their liquidation preferences or conversion values, whichever would be greater, as though the Company was sold on the valuation
date. A DLOM is then applied to arrive at an indication of value for the common stock.

 • Hybrid Method (“Hybrid Method”). The Hybrid Method computes a probability-weighted value across varying
scenarios: the OPM, the CVM and an IPO of the Company. Weighting allocations are assigned to the OPM, the CVM, and an IPO of the Company
factoring in the probability of possible future liquidity events.

In order for the Board to determine the estimated
fair value of the common stock, the Hybrid Method was utilized for the independent third-party valuation of the Company’s common
stock as of June 30, 2021 (the “June 2021 Valuation”), December 31, 2022 (the “December 2022
Valuation”), July 31, 2023 (the “July 2023 Valuation”), and November 30, 2023 (the
 “November 2023 Valuation”). Equity value for each liquidity event scenario utilized in the June 2021
Valuation, December 2022 Valuation, July 2023 Valuation, and November 2023 Valuation (collectively, the “Hybrid
Method Valuations”) was weighted based on the probability of each event’s occurrence. In the IPO scenarios discussed
below, the Company assumed that all outstanding shares of the Company’s convertible preferred stock would be converted into shares
of common stock. In the scenario involving a potential sale of the Company, the Company allocated the value per share by taking into account
the liquidation preferences of the convertible preferred stock, consistent with the method outlined in the Practice Guide.

Boston      Los Angeles      New York      San Diego      San Francisco      toronto       Washington

MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C.

FOIA CONFIDENTIAL TREATMENT REQUESTED PURSUANT TO 17 C.F.R. § 200.83

BY ARRIVENT BIOPHARMA, INC.
 IN CONNECTION WITH REGISTRATION STATEMENT ON FORM S-1 (FILE NO. 333-276397)

    MINTZ

 January 11, 2024
 Page 4

At each stock option grant date, the Board evaluated
any recent events and their potential impacts on the estimated fair value per share of the common stock. For grants of stock options made
on dates for which there was no contemporaneous independent third-party valuation, the Board determined the estimated fair value of the
common stock on the date of grant taking into consideration the immediately preceding valuation report as well as other pertinent information
available to it at the time of the grant.

For the options granted prior to June 1, 2023,
the Company utilized the Hybrid Method in the June 2021 Valuation and December 2022 Valuation, both of which combine elements
of the OPM and CVM methods, as the basis for the value of its common shares at the date of the option grant. In addition, in early June 2021,
the Company entered into a Series A preferred stock purchase agreement (“Series A Purchase Agreement”)
with third party investors, pursuant to which in early June 2021 and in January 2022, the Company sold an aggregate of 150,000,000
shares of Series A convertible preferred stock at a per share price of $1.00, for aggregate gross proceeds of $150.0 million (the
 “Series A Financing”). The OPM utilized the back-solve method to determine equity value in the OPM scenario where the future
raises in January 2022 were considered as warrants. The back-solve method is a market approach that derives an implied total equity
value from the sale price of the Company’s equity securities in a recent arm’s length transaction.

 Given the stage of the Company’s
assets at the time of the Series A Financing in early June 2021, it was apparent that a number of key inflection points
needed to occur prior to reaching a level whereby a robust negotiation dynamic could be assumed. These factors supported the
development of a partial optionality model and the inclusion of the CVM approach. Furthermore, the June 2021
Valuation took into account the Company’s internally generated intellectual property as an intangible asset and the license
agreement entered into by and between the Company and Shanghai Allist Pharmaceuticals Co. Ltd. (“Allist”)
in June 2021 when determining the value of the Company. The valuation also took into consideration the Company’s plan to
file an investigational new drug (“IND”) application with the U.S. Food and Drug Administration
(“FDA”) to further develop furmonertinib in patients with epidermal growth factor receptor
(“EGFR”) mutant non-small cell lung cancer (“NSCLC”), and potentially other
solid tumors, by the end of 2021.

In mid-December 2022, the Company entered
into a Series B preferred stock purchase agreement (“Series B Purchase Agreement”) with third party
investors, pursuant to which in mid-December 2022 and in March 2023, the Company sold an aggregate of 147,619,034 shares of
Series B convertible preferred stock at a per share price of $1.05, for aggregate gross proceeds of $155.0 million (the “Series B
Financing”). As a result of the initial closing of the Series B Financing in mid-December 2022 and the anticipated
second closing in March 2023, in the December 2022 Valuation, the Company continued to utilize the Hybrid Method incorporating
both the OPM and the CVM methods for substantially the same considerations as discussed above with a slightly different allocation of
probability weighting between the two methods. The OPM utilized the back-solve method to determine equity value in the OPM scenario where the future raises in March 2023 were considered
as warrants.

Boston      Los Angeles      New York      San Diego      San Francisco      toronto       Washington

MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C.

FOIA CONFIDENTIAL TREATMENT REQUESTED PURSUANT TO 17 C.F.R. § 200.83

BY ARRIVENT BIOPHARMA, INC.
 IN CONNECTION WITH REGISTRATION STATEMENT ON FORM S-1 (FILE NO. 333-276397)

    MINTZ

 January 11, 2024
 Page 5

Given
that the Company reached a number of key value inflection points later in 2023 which set the Company on a path toward a potential IPO,
the CVM approach was removed from the Hybrid Method unitized in the August 2023 Valuation and replaced with