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 November 20, 2025

Christoph Antz
Chief Executive Officer
Veraxa Biotech Holding AG
Talacker 35
8001 Zurich, Switzerland

Adeel Rouf
Chief Executive Officer
Voyager Acquisition Corp./Cayman Islands
131 Concord Street
Brooklyn, NY 11201

 Re: Veraxa Biotech Holding AG
 Amendment No. 2 to Registration Statement on Form F-4
 September 29, 2025
 File No. 333-289108
Dear Christoph Antz and Adeel Rouf:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.

Amendment 2 to Form F-4 filed on September 29, 2025
Our Dual-Targeting/AND-Gate Concept, page 231

1. We note your response to prior comment 24 and reissue in part. Please
revise the
 graphic appearing on page 231 to remove the arrows implying that your
product
 candidates will be safer and more effective than approved therapies.
 November 20, 2025
Page 2
Our Pipeline, page 268

2. Please revise your pipeline table to condense the preclinical phases to
no more
 than two columns. In addition, the progress arrow for VX-A901 indicates
that Phase II
 in underway. However, disclosure elsewhere in the prospectus states that
further
 evaluation in a Phase II study is planned, suggesting that Phase II has
not yet
 commenced. Please revise the table as necessary so that the progress
arrows
 accurately depict the current state of development for each product
candidate. Please
 also revise to clarify if there is an active IND for this trial.
3. We note your response to prior comment 32 and reissue. Please further
revise your
 statement claiming that your DAR 4 anti-HER2 ADC showed "efficacy"
comparable
 to Enhertu, as it improperly implies this candidate will be successful
in clinical trials.
 We would not object to disclosure presenting the objective data observed
in the study
 without making conclusions as to the efficacy of your product candidate.
Partnerships And Collaborations, page 277

4. We note in your response that you will file the Hemibody license
agreement with
 Cherry Biolabs GmbH in a subsequent amendment. Please also revise this
section to
 include a description of the Hemibody license agreement and ensure that
you disclose
 the rights and obligations of both parties, any term and termination
provisions,
 aggregate amounts paid or due under these agreements and any amounts
paid to date.
Company Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Results of Operations
Research and Development Expenses, page 305

5. We note your response to comment 36. Please revise your filing to
disclose if you
 track any of your research and development costs by product candidate.
To the extent
 you track any your research and development costs by product candidate,
revise to
 also provide a breakdown of the tracked amounts for each period
presented. To the
 extent you do not track any of your research and development costs by
product
 candidate, disclose that fact and explain why not. To the extent you
begin tracking
 your costs by product candidate in future periods, confirm you will
provide a
 breakdown at that point.

 Please contact Tara Harkins at 202-551-3639 or Kevin Vaughn at
202-551-3494 if
you have questions regarding comments on the financial statements and related
matters. Please contact Tyler Howes at 202-551-3370 or Chris Edwards at
202-551-6761
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
 November 20, 2025
Page 3
cc: Andrew Tucker, Esq.
 Michael J. Blankenship, Esq.
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