SecProbe.io

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 May 7, 2025

Bruce Jacobs
Chief Financial Officer
Kymera Therapeutics, Inc.
500 North Beacon Street, 4th Floor
Watertown, MA 02472

 Re: Kymera Therapeutics, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2024
 File No. 001-39460
Dear Bruce Jacobs:

 We have completed our review of your filings. 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.

 Sincerely,

 Division of Corporation
Finance
 Office of Life Sciences
</TEXT>
</DOCUMENT>

CORRESP
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 VIA EDGAR
 April 30, 2025 Office of Life Sciences
 Division of Corporation Finance United States Securities and
Exchange Commission 100 F Street, N.E. Washington, D.C.
20549-3628 Attention: Tara Harkins, Gary Newberry

 Re:
 Kymera Therapeutics, Inc.
   Form 10-K for Fiscal Year Ended December 31, 2024
   File No. 001-39460
 Ladies and Gentlemen, Kymera Therapeutics, Inc. (the
“Company,” “we,” “us” or “our”) is submitting this letter in response to comments of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the
“Commission”), received by letter dated April 25, 2025 (the “Comment Letter”), relating to the Company’s Form 10-K for the fiscal year ended December 31, 2024 filed with the
Commission on February 27, 2025 (the “Form 10-K”). For your convenience, the Staff’s comment is reproduced in bold type below, followed by the Company’s response thereto.
 Form 10-K for Fiscal Year Ended December 31, 2024
 Note 13 - Net Loss per Share, page F-32

 1.
 We note the 15.2 million pre-funded warrants outstanding
disclosed in Note 1 and the risk of potential dilution described on page 76. Please revise future filings to provide the following:

 •

 Reconcile the denominator used for basic per share computations to show the effect of all securities that
impact earnings per share. Refer to ASC 260-10-50-1 and 260-10-55-53.

 •

 Describe any reasonably likely material changes in the mix of your capital resources necessary to
understand your financial condition due to the dilution of the warrants within your MD&A in Item 7. Refer to Item 303(b)(1)(ii)(B) of Regulation S-K.
 Response : In response to the Staff’s comment, in future filings beginning with the Company’s Form
 10-Q for the fiscal quarter ended March 31, 2025, as appropriate, the Company will reconcile the denominator used for basic per share computations to show the effect of all securities that impact earnings
per share and describe any reasonably likely material changes in the mix of the Company’s capital resources necessary to understand the Company’s financial condition due to the dilution of the warrants within the Company’s
Management’s Discussion and Analysis of Financial Condition and Results of Operations.

 April 30, 2025
 Page 2
 If you or any other member of the Staff have any questions regarding the foregoing responses,
would like to discuss any of the matters covered in this letter, or otherwise require additional information, please do not hesitate to contact the undersigned at (857) 285-5314.

 Sincerely,

 /s/ Bruce Jacobs

 Bruce Jacobs

 Chief Financial Officer

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 April 25, 2025

Bruce Jacobs
Chief Financial Officer
Kymera Therapeutics, Inc.
500 North Beacon Street, 4th Floor
Watertown, MA 02472

 Re: Kymera Therapeutics, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2024
 File No. 001-39460
Dear Bruce Jacobs:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2024
Note 13 - Net Loss per Share, page F-32

1. We note the 15.2 million pre-funded warrants outstanding disclosed in
Note 1 and the
 risk of potential dilution described on page 76. Please revise future
filings to provide
 the following:

 Reconcile the denominator used for basic per share computations to
show the
 effect of all securities that impact earnings per share. Refer to
ASC 260-10-50-1
 and 260-10-55-53.
 Describe any reasonably likely material changes in the mix of your
capital
 resources necessary to understand your financial condition due to
the dilution of
 the warrants within your MD&A in Item 7. Refer to Item
303(b)(1)(ii)(B) of
 Regulation S-K.
 April 25, 2025
Page 2

 In closing, 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.

 Please contact Tara Harkins at 202-551-3639 or Gary Newberry at
202-551-3761 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
</TEXT>
</DOCUMENT>

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 VIA EDGAR

June 28, 2021

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 Office of Life
Sciences

 100 F Street, N.E.

 Washington, D.C. 20549

Attention: Irene Paik

Re:
 Kymera Therapeutics, Inc.

 Registration Statement on Form S-1 (File No. 333-257476)

 Request for Acceleration of Effective Date

Ladies and Gentlemen:

 In accordance with Rule
461 under the Securities Act of 1933, as amended (the “Act”), we, as representatives of the several underwriters, hereby join in the request of Kymera Therapeutics, Inc. (the “Company”) for acceleration of the effective date of
the above-named Registration Statement so that it becomes effective at 4:30 PM, Eastern Time, on June 30, 2021, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Goodwin Procter LLP, request by
telephone that such Registration Statement be declared effective.

 Pursuant to Rule 460 under the Act, we, as representatives of the
several underwriters, wish to advise you that there will be distributed to each Underwriter or dealer, who is reasonably anticipated to participate in the distribution of the securities, as many copies of the proposed form of preliminary prospectus
as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

 We, the undersigned, as representatives of the
several underwriters, have complied and will comply, and we have been informed by the participating underwriters that they have complied and will comply, with the requirements of Rule 15c2-8 under the
Securities Exchange Act of 1934, as amended.

 Very truly yours,

 Acting severally on behalf of themselves

and the several underwriters,

 By:

 Morgan Stanley & Co. LLC

 By:

 /s/ Chris Rigoli

 Name:  Chris Rigoli

 Title:    Vice President

 By:

 J.P. Morgan Securities LLC

 By:

 /s/ David Ke

 Name:  David Ke

 Title:    Managing Director

 By:

 Cowen and Company, LLC

 By:

 /s/ Bill Follis

 Name:  Bill Follis

Title:    Managing Director

[Signature Page to Underwriters’ Acceleration Request]

CORRESP
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CORRESP

 VIA EDGAR

June 28, 2021

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 Mail Stop 4561

 100 F Street, N.E.

 Washington, D.C. 20549

Re:
 Kymera Therapeutics, Inc.

 Acceleration Request for Registration Statement on Form S-1

 File No. 333-257476

Ladies and Gentlemen,

 Pursuant to Rule 461 under the
Securities Act of 1933, as amended (the “Act”), Kymera Therapeutics, Inc. (the “Company”) hereby requests that the effective date of the above-referenced registration statement (the “Registration
Statement”) be accelerated to June 30, 2021, at 4:30 p.m., Eastern Time, or as soon thereafter as practicable, unless we or our outside counsel, Goodwin Procter LLP, request by telephone that such Registration Statement be declared
effective at some other time. In making this acceleration request, the Company acknowledges that it is aware of its responsibilities under the Act.

 Once
the Registration Statement is effective, please orally confirm the event with our counsel, Goodwin Procter LLP by calling William D. Collins at 617-570-1447. We also
respectfully request that a copy of the written order from the Securities and Exchange Commission (the “Commission”) verifying the effective time and date of the Registration Statement be sent to our counsel, William D. Collins of
Goodwin Procter LLP, by facsimile to (617) 321-4422.

 If you have any questions regarding this request, please
contact William D. Collins of Goodwin Procter LLP at (617) 570-1447.

 Sincerely,

 KYMERA THERAPEUTICS, INC.

 /s/ Nello Mainolfi

Nello Mainolfi

President and Chief Executive Officer

Cc:
 Bruce Jacobs, Chief Financial Officer, Kymera Therapeutics, Inc.

Karen Martin, Vice President and Head of Legal, Kymera Therapeutics, Inc.

William D. Collins, Esq., Goodwin Procter LLP

United States securities and exchange commission logo
March 19, 2021
Nello Mainolfi
Founder, President and Chief Executive Officer
Kymera Therapeutics, Inc.
200 Arsenal Yards Blvd., Suite 230
Watertown, Massachusetts 02472
Re:Kymera Therapeutics, Inc.
Draft Registration Statement on Form S-1
Submitted March 17, 2021
CIK No. 0001815442
Dear Dr. Mainolfi:
            This is to advise you that we do not intend to review your registration statement.
            We request that you publicly file your registration statement no later than 48 hours prior
to the requested effective date and time. Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.
            Please contact Irene Paik at 202-551-6553 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Nicole Daley - Goodwin Procter LLP

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CORRESP

 VIA EDGAR

August 18, 2020

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 Office of Life
Sciences

 100 F Street, N.E.

 Washington, D.C. 20549

Attention:
 Abby Adams

Celeste Murphy

 Vanessa Robertson

 Daniel Gordon

Re:
 Kymera Therapeutics, Inc.

Registration Statement on Form S-1 (File
No. 333-240264)

 Request for Acceleration of Effective Date

Ladies and Gentlemen:

 In
accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), we, as representatives of the several underwriters, hereby join in the request of Kymera Therapeutics, Inc. (the “Company”) for acceleration of
the effective date of the above-named Registration Statement so that it becomes effective at 4:01 PM, Eastern Time, on August 20, 2020, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Goodwin
Procter LLP, request by telephone that such Registration Statement be declared effective.

 Pursuant to Rule 460 under the Act, we, as
representatives of the several underwriters, wish to advise you that approximately 1,130 copies of the Preliminary Prospectus included in the above-named Registration Statement, as amended, were distributed during the period from July 31, 2020
through the date hereof, to prospective underwriters, institutions, dealers and others.

 We, the undersigned, as representatives of the
several underwriters, have complied and will comply, and we have been informed by the participating underwriters that they have complied and will comply, with the requirements of Rule 15c2-8 under the
Securities Exchange Act of 1934, as amended.

Very truly yours,

Acting severally on behalf of themselves and the several underwriters,

By:

Morgan Stanley & Co. LLC

By:

 /s/ Chris Rigoli

Name: Chris Rigoli

Title:   Vice President

By:

BofA Securities, Inc.

By:

 /s/ Greg Butz

Name: Greg Butz

Title:   Managing Director

By:

Cowen and Company, LLC

By:

 /s/ Bill Follis

Name: Bill Follis

Title:   Managing Director

 [Signature Page to Underwriters’ Acceleration Request]

CORRESP
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CORRESP

 VIA EDGAR

August 18, 2020

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 Office of Life
Sciences

 100 F Street, N.E.

 Washington, D.C. 20549

Attention:
 Abby Adams

Celeste Murphy

 Vanessa Robertson

 Daniel Gordon

Re:
 Kymera Therapeutics, Inc.

Acceleration Request for Registration Statement on Form S-1

File No. 333-240264

Dear Ms. Adams,

 Pursuant to Rule 461
under the Securities Act of 1933, as amended (the “Act”), Kymera Therapeutics, Inc. (the “Company”) hereby requests that the effective date of the above-referenced registration statement (the “Registration
Statement”) be accelerated to August 20, 2020, at 4:01 p.m., Eastern Time, or as soon thereafter as practicable, unless we or our outside counsel, Goodwin Procter LLP, request by telephone that such Registration Statement be declared
effective at some other time. In making this acceleration request, the Company acknowledges that it is aware of its responsibilities under the Act.

Once the Registration Statement is effective, please orally confirm the event with our counsel, Goodwin Procter LLP by calling Gabriela
Morales-Rivera at (617) 570-1329. We also respectfully request that a copy of the written order from the Securities and Exchange Commission verifying the effective time and date of the Registration Statement
be sent to our counsel, Goodwin Procter LLP, Attention: Gabriela Morales-Rivera, by facsimile to (617) 801-8858.

 If you have any questions regarding this request, please contact Gabriela Morales-Rivera of Goodwin Procter
LLP at (617) 570-1329.

Sincerely,

KYMERA THERAPEUTICS, INC.

 /s/ Nello Mainolfi

Nello Mainolfi, Ph.D.

President and Chief Executive Officer

cc:
 Nello Mainolfi, Ph.D., Kymera Therapeutics, Inc.

Bruce Jacobs, CFA, MBA, Kymera Therapeutics, Inc.

William D. Collins, Esq., Goodwin Procter LLP

Gabriela Morales-Rivera, Esq., Goodwin Procter LLP

[Signature Page to Acceleration Request]

CORRESP
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CORRESP

 Goodwin Procter LLP

 100 Northern
Avenue

 Boston, MA 02210

goodwinlaw.com

 +1 617 570 1000

 August 13, 2020

Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences 100 F Street, N.E.

Washington, D.C. 20549

Attention:

 Abby Adams

 Celeste Murphy

 Vanessa Robertson

 Daniel Gordon

Re:

 Kymera Therapeutics, Inc.

Registration Statement on Form S-1

Filed July 31, 2020

 File No. 333-240264

 Ladies and Gentlemen,

On behalf of our client, Kymera Therapeutics, Inc. (the “Company”), we are responding to the comments from the Staff
(the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to the Company’s Registration Statement on Form S-1 (the “Registration
Statement”) contained in the Staff’s letter dated August 11, 2020 (the “Comment Letter”). In response to the comments set forth in the Comment Letter, the Company has revised the Registration Statement and is
submitting Amendment No. 2 to Registration Statement on Form S-1 (the “Amended Registration Statement”) together with this response letter. The Amended Registration Statement also
contains certain additional updates and revisions.

 Set forth below are the Company’s responses to the Staff’s comments in the
Comment Letter. The responses and information below are based on information provided to us by the Company. For convenience, the Staff’s comments are repeated below in italics, followed by the Company’s response to the comments
as well as a summary of the responsive actions taken. We have included page numbers to refer to the location in the Amended Registration Statement submitted herewith where the revised language addressing a particular comment
appears. Capitalized terms used but not defined herein are as defined in the Amended Registration Statement.

 Registration Statement on Form S-1

Prospectus Summary

 Overview, page 1

1.
 Refer to comment 2. The products in your discovery pipeline are not sufficiently advanced or under your
control to emphasize in the pipeline table. Revise to eliminate the discovery pipeline.

RESPONSE:    The Company respectfully advises the Staff that it has revised the pipeline table on pages 2 and 102
of the Amended Registration Statement in response to the Staff’s comment to eliminate the discovery pipeline from the table.

RESPONSE:

2.
 Refer to comment 3. Revise the pipeline to include individual columns for Phases 2 and 3, or tell us on what
basis you believe you will be able to combine your Phase 2 and 3 studies for all of the product candidates listed in this table.

RESPONSE:    The Company respectfully advises the Staff that it has revised the pipeline table on pages 2 and 102
of the Amended Registration Statement in response to the Staff’s comment to include individual columns for Phases 2 and 3.

3.
 Refer to comment 4. Revise the pipeline table to clearly distinguish between the application for which you
will seek regulatory approval for KT-474. In doing so, explain or delete the reference to “others.”

RESPONSE:    The Company respectfully advises the Staff that it has revised the pipeline table on pages 2 and 102
of the Amended Registration Statement in response to the Staff’s comment to clarify that the Company anticipates seeking regulatory approval for KT-474 in one or more indications, including each of
hidradenitis suppurativa (HS), atopic dermatitis (AD) and rheumatoid arthritis (RA), and to the reference in the table to “others.”

 Risk
Factors

 Risks Related to Intellectual Property, page 46

4.
 We note your response to comment 8. As you take the position Kymera will not be required to change its name,
revise to add a risk factor specifically outlining the risks if you are unable to trademark Kymera in the United States. Expand on your disclosure that you “may not be able to compete effectively and [y]our business may be adversely
affected.”

 RESPONSE:    The Company respectfully advises the Staff that it has
revised the disclosure on page 46 of the Amended Registration Statement in response to the Staff’s comment to clarify that the Company would be able to use and enforce its trademark and trade name in the United States even without registration,
as trademark registration is discretionary rather than mandatory in the United States. The Company further clarifies in the revised disclosure, that if the Company is unable to obtain a registration of the KYMERA mark in the European Union, it may
not be able to as effectively enforce its mark against third parties in most of the member countries of the European Union, as unregistered trademarks do not enjoy protection against infringement by third parties under European Union law and only a
few of the member countries offer broad protection for unregistered marks under their national laws.

 Business Overview, page 100

5.
 Refer to comment 13. You continue to describe your potential products as potent on pages 1, 81, 99, 103 and
elsewhere. Revise these and all similar statements in the document.

 RESPONSE:    The
Company respectfully advises the Staff that it has revised the disclosure on pages 1, 2, 3, 81, 100, 102, 109, 110, 111, 115, 123, 124, 126 and 132 of the Amended Registration Statement in response to the Staff’s comment to remove references to
the Company’s potential products as “potent” and to clarify the Company’s statements.

 Sincerely,

 /s/Gabriela Morales-Rivera

Gabriela Morales-Rivera

cc:
 Nello Mainolfi, Kymera Therapeutics, Inc.

Bruce Jacobs, Kymera Therapeutics, Inc.

William D. Collins, Goodwin Procter LLP

Sarah Ashfaq, Goodwin Procter LLP

United States securities and exchange commission logo
August 11, 2020
Nello Mainolfi, Ph.D.
President and Chief Executive Officer
Kymera Therapeutics, Inc.
300 Technology Square, 2nd Floor
Cambridge, MA 02139
Re:Kymera Therapeutics, Inc.
Registration Statement on Form S-1
Filed July 31, 2020
Amendment No. 1 to Registration Statement on Form S-1
Filed August 5, 2020
File No. 333-240264
Dear Dr. Mainolfi:
            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
Prospectus Summary
Overview, page 1
1.Refer to comment 2.  The products in your discovery pipeline are not sufficiently
advanced or under your control to emphasize in the pipeline table.  Revise to eliminate the
discovery pipeline.
2.Refer to comment 3.  Revise the pipeline to include individual columns for Phases 2 and
3, or tell us on what basis you believe you will be able to combine your Phase 2 and 3
studies for all of the product candidates listed in this table.

 FirstName LastNameNello Mainolfi, Ph.D.
 Comapany NameKymera Therapeutics, Inc.
 August 11, 2020 Page 2
 FirstName LastName
Nello Mainolfi, Ph.D.
Kymera Therapeutics, Inc.
August 11, 2020
Page 2
3.Refer to comment 4.  Revise the pipeline table to clearly distinguish between the
application for which you will seek regulatory approval for KT-474.  In doing so, explain
or delete the reference to "others."
Risk Factors
Risks Related to Intellectual Property, page 46
4.We note your response to comment 8.  As you take the position Kymera will not be
required to change its name, revise to add a risk factor specifically outlining the risks if
you are unable to trademark Kymera in the United States.  Expand on your disclosure that
you "may not be able to compete effectively and [y]our business may be adversely
affected."
Business Overview, page 100
5.Refer to comment 13.  You continue to describe your potential products as potent on
pages 1, 81, 99, 103 and elsewhere.  Revise these and all similar statements in the
document.
            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.
            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 Vanessa Robertson at (202) 551-3649 or Daniel Gordon at (202) 551-
3486 if you have questions regarding the financial statements and related matters.  Please contact
Abby Adams at (202) 551-6902 or Celeste Murphy at (202) 551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       William D. Collins, Esq.

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 Goodwin Procter LLP

 100 Northern Avenue

Boston, MA 02210

goodwinlaw.com

 +1 617 570 1000

 FOIA CONFIDENTIAL TREATMENT REQUESTED BY KYMERA THERAPEUTICS, INC.

CERTAIN PORTIONS OF THIS LETTER AS FILED VIA EDGAR HAVE BEEN OMITTED AND FILED SEPARATELY WITH THE COMMISSION. CONFIDENTIAL TREATMENT HAS BEEN REQUESTED
WITH RESPECT TO THE OMITTED PORTIONS. OMITTED INFORMATION HAS BEEN REPLACED IN THIS LETTER AS FILED VIA EDGAR WITH A PLACEHOLDER IDENTIFIED BY THE MARK “[***].”

 August 5, 2020

 VIA
EDGAR AND E-MAIL

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 Office of Life Sciences

100 F Street, N.E.

 Washington, D.C. 20549

Attention:  Abby Adams

        Celeste Murphy

        Vanessa Robertson

        Daniel Gordon

Re:

Kymera Therapeutics, Inc.

Registration Statement on Form S-1

File No. 333-240264

CIK No. 0001815442

 Ladies and Gentlemen:

On behalf of Kymera Therapeutics, Inc. (the “Company”), in response to comments from the staff (the “Staff”) of the U.S.
Securities and Exchange Commission (the “Commission”) received by letter dated July 17, 2020 (the “Comment Letter”) relating to the Company’s Registration Statement on Form
S-1, originally confidentially submitted to the Commission on June 22, 2020 and subsequently filed by the Company with the Commission on July 31, 2020 (File
No. 333-240264) (the “Registration Statement”), we submit this supplemental letter to further address comment 12 of the Comment Letter.

 August 5, 2020

  Page
 2

 Because of the commercially sensitive nature of 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.

 We confirm on behalf of the Company that, prior to circulating copies of the preliminary prospectus in connection with the
offering, the Company will file a pre-effective amendment to the Registration Statement that will include all information other than information that may be excluded in reliance upon Rule 430A of Regulation C,
and the actual price range to be included in such amendment which will comply with the Staff’s interpretation regarding the parameters of a bona fide price range.

The Company expects to reflect the Stock Split (as defined below) in a pre-effective amendment to the Registration
Statement that includes the actual price range; however, all dollar amounts and per share amounts in this letter are pre-Stock Split, and therefore, consistent with the Registration Statement.

The Company respectfully requests that the bracketed information contained in this letter be treated as confidential information pursuant to Rule 83
promulgated by the Commission, 17 C.F.R. §200.8, and that the Commission provide timely notice to Bruce Jacobs, Chief Financial Officer, Kymera Therapeutics, Inc., 200 Arsenal Yards Blvd., Suite 230, Watertown, Massachusetts 02472 before it
permits any disclosure of the bracketed information in this letter.

 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.

12.
 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 IPO and the estimated offering price. This information will help facilitate our review of
your accounting for equity issuances including stock compensation and beneficial conversion features.

 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 equity awards and the reasons for the
differences between the recent valuation of its common stock and the estimated offering price for its initial public offering (“IPO”).

CONFIDENTIAL TREATMENT REQUESTED BY KYMERA THERAPEUTICS, INC.

 August 5, 2020

  Page
 3

 Preliminary IPO Price Range

The Company advises the Staff that it preliminarily estimates a price range of approximately [***] to [***] per share (the “Preliminary Price
Range”) for its IPO, before giving effect to a reverse stock split that the Company plans to implement prior to effectiveness of the Registration Statement (the “Stock Split”). 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.

Determining the Fair Value of Common Stock Prior to the IPO

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, considering the Company’s most recent third-party valuations of its common stock and the Board’s assessment
of additional objective and subjective factors that it believed were relevant and which may have changed from the date of the most recent third-party valuation through the date of the grant. The Company’s most recent third-party valuations of
its common stock, and the results of retrospective valuations of the Company’s October 24, 2018, March 31, 2019 and December 31, 2019 valuations for fair value determination purposes, were as follows:

 Date of Third-Party Valuation

Date of Board Approval

Fair Market Value
of Common Stock
per Share at Time
of Grant

Fair Value of
Common Stock
per Share as of
Grant Date

 October 24, 2018

November 1, 2018

$
0.82

$
1.00
(1)

 March 31, 2019

May 23, 2019

$
1.30

$
1.55
(1)

 December 31, 2019

N/A

N/A

$
2.93
(1)

 March 11, 2020

May 14, 2020

$
3.34

$
3.34
(2)

 July 17, 2020

July 29, 2020

$
6.48

$
6.48
(2)

(1)
 Reflects the results of retrospective valuations of the Company’s October 24, 2018, March 31,
2019 and December 31, 2019 valuations for fair value determination purposes.

(2)
 Reflects no change from fair value determination purposes from original valuation determination.

 CONFIDENTIAL TREATMENT
REQUESTED BY KYMERA THERAPEUTICS, INC.

 August 5, 2020

  Page
 4

 As presented in “Management’s Discussion and Analysis of Financial Condition and Results of
Operations – Revenue Recognition – Determination of the Fair Value of Common Stock” in the Registration Statement, the following table summarizes by grant date the number of shares subject to options granted between November 1,
2018 and July 31, 2020, the per share exercise price of the options and the fair value of common stock underlying the options on each grant date:

 Grant Date

Award type

Number of
shares subject to
awards granted

Per share
exercise price of
awards

Fair value per
common share
on grant date

Per share estimated
fair value of awards(1)

 November 1, 2018

Stock Options

946,003

$
0.82

$
1.00

$
0.66

 November 1, 2018

Restricted Stock

1,886,775

$
N/A

$
1.00

$
1.00

 May 23, 2019

Stock Options

2,186,245

$
1.30

$
1.55

$
1.06

 August 29, 2019

Stock Options

1,186,520

$
1.30

$
1.55

$
1.04

 November 14, 2019

Stock Options

1,676,343

$
1.30

$
1.55

$
1.07

 January 18, 2020

Stock Options

467,500

$
1.30

$
2.93

$
2.32

 May 14, 2020

Stock Options

2,006,600

$
3.34

$
3.34

$
2.26

 July 29, 2020

Stock Options

470,000

$
6.48

$
6.48

$
4.24

(1)
 The per share estimated fair value of options reflects the weighted-average fair value of options granted on
each grant date determined using the Black-Scholes option-pricing model.

 These third-party valuations were performed in accordance with
the guidance outlined in the American Institute of Certified Public Accountants’ Accounting and Valuation Guide, Valuation of Privately-Held-Company Equity Securities Issued as Compensation, and were prepared using a hybrid between
the probability-weighted expected return method (“PWERM”) and the option-pricing method (“OPM”), estimating the probability-weighted value across multiple scenarios but using the OPM to estimate the allocation of
value in at least one scenario.

 The PWERM involves a forward-looking analysis of the potential future outcomes available to the enterprise, the
estimation of future value and present value under each outcome, and the application of a probability factor to each outcome as of the valuation date. Unlike the PWERM, the OPM begins with the current equity value and estimates the future
distribution of outcomes using a lognormal distribution around that current value. The OPM treats common and preferred stock as call options on the enterprise’s equity value, with exercise prices based on the liquidation preference of the
preferred stock. In the PWERM and the OPM, a discount for lack of marketability (“DLOM”) is applied to the value indicated for the common stock.

Each of the Company’s most recent third-party valuations, which were used, in part, by the Board to determine the fair market value of the Company’s
common stock as of the grant date of each option award, considered two future-event scenarios: an IPO scenario and a sale scenario. The equity value of the Company in each future-event scenario was determined using market approaches. The IPO
scenario assumed that all shares of preferred stock would convert into shares of common stock and would no longer have the liquidation preferences and preferential rights attributable to such preferred stock as compared to the common stock prior to
the IPO. Each valuation probability-weighted the IPO scenario and the sale scenario based on the Company’s assessment of its overall performance and market conditions at that time, including then-current IPO valuations of similarly situated
companies, and expectations as to the timing and likely prospects of the future-event scenarios. For each future-event scenario, the Company then applied a DLOM, each determined by a put option analysis that considered the timing of each
future-event scenario.

 CONFIDENTIAL
TREATMENT REQUESTED BY KYMERA THERAPEUTICS, INC.

 August 5, 2020

  Page
 5

 October 24, 2018 Valuation

The Board relied, in part, on the results of the October 24, 2018 valuation in its determination of the fair value of common stock of $0.82 per share for
its option grants of 946,003 shares on November 1, 2018. To allocate value to the Company’s securities, the October 24, 2018 valuation utilized the hybrid method of both the OPM and a PWERM, which included IPO and acquisition
scenarios that were probability weighted based on their expected likelihoods of occurring, and took into account the proposed capital structure, preferred stock terms and valuation assumptions and likelihood of completion of the Company’s
financing round of Series B convertible preferred stock in November 2018 at a price of $4.06 per share.

 The PWERM used in the October 24, 2018
valuation included the following three scenarios: (i) the short-term IPO scenario, which contemplated the closing of an IPO in October 2019, (ii) the long-term IPO scenario, which contemplated the closing of an IPO in October 2020, and
(iii) the sale scenario, which contemplated a sale of the Company. The equity value of the Company in each scenario was determined using the market approach, specifically the Guideline Transactions Method.

The DLOM applied to the fair value of common stock was estimated using a put option analysis. Key assumptions used by the Company in the October 24, 2018
valuation were as follows:

Scenario

 Probability

Weighting

DLOM

Per Share Common
Stock Price

 IPO (Short-Term)

5
%

15.0
%

$
3.95

 IPO (Long-Term)

5
%

20.0
%

$
3.97

 Sale

90
%

35.0
%

$
0.67

 Between October 24, 2018 and November 1, 2018, the Company continued to operate its business in the ordinary course
and there were no significant developments in its business. As a result, the Board determined that the fair value of the Company’s common stock remained at $0.82 from October 24, 2018 to November 1, 2018. In the first half of 2020,
the Company performed a retrospective valuation to adjust certain valuation methodologies and assumptions around future-event scenarios for purposes of determining stock compensation expense with respect to the grants approved on November 1,
2018, which valuation resulted in a fair value determination of $1.00 per share.

CONFIDENTIAL TREATMENT REQUESTED BY KYMERA THERAPEUTICS, INC.

 August 5, 2020

  Page
 6

 March 31, 2019 Valuation

The Board relied, in part, on the results of March 31, 2019 valuation in its determination of the fair value of common stock of $1.30 per share for its
option grants of 5,516,608 shares from May 23, 2019 to January 18, 2020. To allocate value to the Company’s securities, the March 31, 2019 valuation utilized the hybrid method of both the OPM and a PWERM, which included IPO and
acquisition scenarios that were probability weighted based on their expected likelihoods of occurring. The March 31, 2019 valuation also took into account the Company’s initial sale of Series B convertible preferred stock in November 2018
at a price of $4.06 per share, for aggregate proceeds of $39.0 million, the potential sale of an additional $26.0 million of Series B preferred stock following the achievement or waiver of certain milestones, and a term sheet relating to
the Collaboration and Option Agreement with Vertex Pharmaceuticals, dated February 24, 2019, which included a proposed investment by Vertex for $20.0 million worth of Series B-1 Preferred Stock at
$6.5366 per share.

 The PWERM used in the March 31, 2019 valuation included the following two scenarios: (i) the short-term IPO scenario, which
contemplated the closing of an IPO in September 2020, and (ii) the sale scenario, which contemplated a sale of the Company. The equity value of the Company in each scenario was determined using the market approach, specifically the Guideline
Transactions Method.

 The DLOM applied to the fair value of common stock was estimated using a put option analysis. Key assumptions used by the Company in
the March 31, 2019 valuation were as follows:

Scenario

 Probability

Weighting

DLOM

Per Share Common
Stock Price

 IPO (Short-Term)

10
%

20.0
%

$
3.69

 Sale

90
%

35.0
%

$
1.31

 Between March 31, 2019 and January 18, 2020, the Company continued to operate its business in the ordinary course
and there were no significant developments in its business, other than the May 2019 closing of its collaboration and investment transactions with Vertex Pharmaceuticals as contemplated by the March 31, 2019 valuation. In the first half of 2020,
the Company performed a retrospective valuation to adjust certain valuation methodologies and assumptions around future-event scenarios for purposes of determining stock compensation expense with respect to the grants approved from May 23, 2019
through November 19, 2019, which valuation resulted in a fair value determination of $1.55 per share.

 With respect to the determination of fair
market value made by the Board in connection with the option grants of 467,500 shares approved on January 18, 2020, in addition to the assumptions and methodologies used in the March 31, 2019 valuatio

CORRESP
1
filename1.htm

CORRESP

 Goodwin Procter LLP

 100
Northern Avenue

 Boston, MA 02210

goodwinlaw.com

 +1 617 570 1000

 July 31, 2020

 Securities
and Exchange Commission

 Division of Corporation Finance

Office of Life Sciences

 100 F Street, N.E.

Washington, D.C. 20549

 Attention: Abby Adams

Celeste Murphy

 Vanessa Robertson

 Daniel Gordon

Re:
 Kymera Therapeutics, Inc.

 Draft Registration Statement on Form S-1

 Submitted June 22, 2020

 CIK No. 0001815442

Ladies and Gentlemen,

 On behalf of our client,
Kymera Therapeutics, Inc. (the “Company”), we are responding to the comments from the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) relating to the
Company’s confidential draft Registration Statement on Form S-1 (the “Draft Registration Statement”) contained in the Staff’s letter dated July 17, 2020 (the
“Comment Letter”). In response to the comments set forth in the Comment Letter, the Company has revised the Draft Registration Statement and is publicly submitting a revised Registration Statement (the “S-1 Registration Statement”) together with this response letter. The S-1 Registration Statement also contains certain additional updates and revisions.

Set forth below are the Company’s responses to the Staff’s comments in the Comment Letter. The responses and information below
are based on information provided to us by the Company. For convenience, the Staff’s comments are repeated below in italics, followed by the Company’s response to the comments as well as a summary of the responsive actions
taken. We have included page numbers to refer to the location in the S-1 Registration Statement submitted herewith where the revised language addressing a particular comment appears. Capitalized
terms used but not defined herein are used herein as defined in the S-1 Registration Statement.

  Page
 2

 Draft Registration Statement on Form S-1

Prospectus Summary

 Overview, page 1

1.
 Define or explain these terms the first time you use them in the document:

•

 “IL-1R/TLR” and
“JAK/STAT” (page 1);

•

 “E3 ligase” (page 2);

•

 “hidradenitis suppurativa” (page 3);

•

 “JAKs” (page 3);

•

 PK/PD modeling (page 4);

•

 “cereblon and von Hippel-Lindau, or VHL” (at pages 100, 103); and

•

 TPD (page 105).

RESPONSE: The Company respectfully advises the Staff that it has revised the disclosure on pages 2, 3, 101, and 103 of the S-1 Registration Statement in response to the Staff’s comment to define or explain the various terms noted.

2.
 Your pipeline appears to include every in-house development program
as well as the program you have licensed to Vertex. Please revise the table to include only those programs that are material to the company. If you believe that every program listed is material, please provide us an analysis explaining your belief.
To the extent the Pegasus Platform remains in your table, revise the disclosure to correspond to the appropriate column of development.

RESPONSE: The Company respectfully advises the Staff that it has revised the table on pages 2 and 102 of the S-1 Registration Statement in response to the Staff’s comment to clarify the stages of development of its programs with additional specificity and to more accurately depict the Company’s development
pipeline, which includes certain programs partnered with Sanofi and Vertex.

 In addition, the Company respectfully advises the staff that
the Company considers each of the programs depicted in the pipeline graphic to be material to the Company and its investors for the following reasons:

•

 Each IRAK4, IRAKIMiD, and STAT3 program depicted in the pipeline graphic, beyond our KT-474 program, reflects a high-priority area of focus of the Company’s most advanced discovery efforts. These programs are all in preclinical development with likely clinical entry in 2021. Though development
candidates have not yet been identified for all of these programs, the Company believes this disclosure is important to investors in light of its efforts to drive its IRAK4, IRAKIMiD, and STAT3 programs to deliver transformative therapies to
patients, as described in its planned use of proceeds;

  Page
 3

•

 With respect to the Company’s IRAK4 and IRAKIMiD programs generally, the significant research and
development costs incurred with respect to IRAK4 and IRAKIMiD in fiscal year 2019 and the first half of 2020 as described in “Management’s Discussion and Analysis of Financial Condition and Results of Operations”;

•

 With respect to the Company’s lead development candidate KT-474
under its IRAK4 program, the current expectation that the Company will move forward with Phase 1 and Phase 2 clinical development in HS, AD and RA, as described on page 120 of the S-1 Registration Statement;

•

 With respect to the Company’s IRAK4 programs beyond its lead development candidate KT-474, the potential milestone payments attributable to the Company’s IRAK4 program under its collaboration with Sanofi described elsewhere in the S-1 Registration
Statement;

•

 With respect to the Company’s STAT3 programs generally, the significant research and development costs
incurred with respect to STAT3 in fiscal year 2019 and the first half of 2020 as described in “Management’s Discussion and Analysis of Financial Condition and Results of Operations,” including an increase of more than four times the
amount of such expense incurred over the same periods in fiscal year 2018 and the first half of 2019;

•

 With respect to the Company’s STAT3 program in autoimmune & fibrotic diseases, the strategic
importance of its efforts in these disease areas given their prevalence in the population, the frequency in these disease areas of biological pathways that include previously undrugged or inadequately drugged targets, and the potential synergies
with the Company’s lead development efforts in IRAK4;

•

 With respect to the Company’s discovery pipeline partnered with Vertex, the potential milestone payments
attributable to those programs under its collaboration with Vertex described elsewhere in the S-1 Registration Statement;

•

 With respect to the Company’s discovery pipeline partnered with Sanofi, the potential milestone payments
attributable to those programs under its collaboration with Sanofi described elsewhere in the S-1 Registration Statement; and

•

 With respect to the Company’s internal discovery pipeline, the significant development efforts and expenses
undertaken in connection with building out its Pegasus Platform and potential validating of our technology beyond our lead programs while leveraging the Company’s capabilities in E3 ligase biology and chemistry that it expects will result in
differentiated and transformative therapies.

  Page
 4

3.
 Please revise your table to include columns showing the various material phases of the development of your
potential products, including, as applicable, discovery, preclinical, development and the various phases of clinical development. Also include an arrow indicating the phase each of your product candidates is in for the various stages of development
for each indicated disease area.

 RESPONSE: The Company respectfully advises the Staff that it has revised the
table on pages 2 and 102 of the S-1 Registration Statement in response to the Staff’s comment to include columns showing the various phases of the development of the Company’s potential products.

4.
 You mention in your summary and highlight in the pipeline table that other potential targets for your KT-474 product, which is the farthest product you have in development, are atopic dermatitis (AD) and rheumatoid arthritis (RA). You also state, however, that your product is not targeting these indications. As
such, revise your summary and pipeline table to remove these references or provide your analysis of why they are material and appropriate for disclosure here.

RESPONSE: The Company respectfully advises the Staff that it has revised the disclosure on pages 2, 102, and 120 of the S-1 Registration Statement in response to the Staff’s comment to clarify that AD and RA are among the indications the Company is evaluating for KT-474. The Company
believes that its current development efforts in AD and RA with respect to KT-474 are material to investors in light of the Company’s currently expected KT-474
Phase 1 and Phase 2 clinical development plan. Specifically, as revised on page 120 of the S-1 Registration Statement, in its planned Phase 1 trial of KT-474, the
Company will work to characterize the pharmacokinetic and pharmacodynamic profile of the recommended Phase 2 dose of KT-474 in an additional cohort of up to 20 AD and HS patients. Based on the results of that
Phase 1 trial, the Company expects to conduct Phase 2 randomized placebo controlled trials for KT-474 in one or more indications including but not limited to AD, HS, and RA.

Our IRAK4, IRAKIMiD, and STAT3 Programs, page 3

5.
 Please revise your statements on pages 3, 125 and elsewhere in the prospectus that certain of your product
candidates are “first-in-class.” These statements imply an expectation of regulatory approval and are inappropriate given the length of time and uncertainty
with respect to securing marketing approval.

 RESPONSE: The Company respectfully advises the Staff that it has
revised the disclosure on pages 4, 127, and 140 of the S-1 Registration Statement in response to the Staff’s comment to remove references to our product candidates as “first-in-class.”

6.
 For KT-474 and IRAKIMiD you state you will submit an IND and initiate phase 1 trial in first half of 2021,
and for IRAKIMiD, you state you expect to do both in the second half of 2021. As you have more control over when you submit the IND, revise to clarify when you expect that to occur for each product.

  Page
 5

 RESPONSE: The Company respectfully advises the Staff that it has revised the
disclosure on pages 2, 3, 81, 100, 101, 102, 113, and 120, to clarify that the Company expects to submit an Investigational New Drug Application, or IND, to the U.S. Food and Drug Administration for KT-474 in
the first half of 2021, and for degraders from its IRAKIMiD and STAT3 programs in the second half of 2021. If approved, the Company expects to initiate a Phase 1 trial for KT-474 in the first half of 2021, and
for its IRAKIMiD and STAT3 programs in the second half of 2021.

 Corporate Information, page 6

7.
 Please provide us with copies of all written communications, as defined in Rule 405 under the Securities
Act, that you, or anyone authorized to do so on your behalf, present to potential investors in reliance on Section 5(d) of the Securities Act, whether or not they retain copies of the communications.

RESPONSE: The Company respectfully advises the Staff that it will provide the Staff, on a confidential basis under separate cover,
copies of all written communications presented to potential investors in reliance on Section 5(d) of the Securities Act, whether or not they retain copies of such communications.

Risk Factors

 Risks Related to Intellectual
Property, page 43

8.
 We note the risk factor on page 46 related to objections to the name Kymera and Kymera Therapeutics.
You disclose that “If we are unable to obtain a registered trademark or establish name recognition based on our trademarks and trade names, we may not be able to compete effectively and our business may be adversely affected.” Is it also
true that you could be forced to change your name and incur additional significant related expenses? Revise the risk factor to further disclose the potential material risks.

RESPONSE: The Company respectfully advises the staff that Novartis AG is disputing the registration of the Company’s name as a
trademark but not the Company’s use of the name. The Company would not be forced to change its name or incur additional significant related expenses in the event the Company is unable to obtain a registered trademark. The Company further
respectfully advises the Staff that it has revised the disclosure on page 46 to clarify this point.

9.
 On page 53, you disclose that “the Leahy-Smith Act has transformed the U.S. patent system into a
“first inventor to file” system. The first-inventor-to-file provisions, however, only became effective on March 16, 2013. Accordingly, it is not yet
clear what, if any, impact the Leahy-Smith Act will have on the operation of our business.” (Emphasis Added). As your company was first incorporated in December 2015, clarify why the Act’s application to you remains unclear.

  Page
 6

 RESPONSE: The Company respectfully advises the Staff that it has revised the
disclosure on page 52 of the S-1 Registration Statement in response to the Staff’s comment to remove references to the Leahy-Smith Act.

Use of Proceeds, page 70

10.
 You state the proceeds will be used for the “advancement” of each of your products. Please expand
your disclosure regarding the proceeds to be used for your product candidates to describe how far in the development process you estimate the allocated proceeds from this offering will enable you to reach.

RESPONSE: The Company respectfully advises the Staff that it has revised the disclosure on page 69 of the
S-1 Registration Statement to expand its disclosure regarding the proceeds to be used for the Company’s product candidates to describe how far in the development process the Company estimates the
allocated proceeds from this offering will enable it to reach.

 Management’s Discussion and Analysis of Financial
Condition and Results of Operations

 Components of Our Results of Operations, page 83

11.
 It appears from page F-24 you have a collaboration agreement with an entity other than Vertex, or a
prior, separate collaboration agreement with Vertex. Revise to disclose that collaboration or provide your analysis why disclosure is not required.

RESPONSE: The Company respectfully advises the Staff that it has revised the disclosure on pages 93 and 140 of the S-1 Registration Statement to disclose the Company’s Collaboration Agreement with GlaxoSmithKline Intellectual Property Development Limited (“GSK”) dated October 3, 2017 (“GSK
Agreement”). The GSK Agreement will be filed by amendment at a later date as Exhibit 10.12 to the S-1 Registration Statement.

Critical Accounting Policies and Estimates

Determination of the Fair Value of Common Stock, page 94

12.
 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 IPO and the estimated offering price. This information will help facilitate our review of
your accounting for equity issuances including stock compensation and beneficial conversion features.

 RESPONSE:
The Company respectfully acknowledges the Staff’s comment and will supplementally provide the requested information once the estimated offering price or range has been determined.

  Page
 7

 Business Overview, page 97

13.
 Here and on pages 103 and 104 you refer to “potent activity” of your potential degraders, your
“highly efficient, selective and potent degraders” with “appropriate pharmaceutical properties” and “potent and specific degraders.” Given the stage of your product development, it appears premature to describe your
product candidates as potent, which implies they are effective. Please revise or advise why this disclosure is appropriate.

RESPONSE: The Company respectfully advises the Staff that it has revised the disclosure on pages 3, 100, 107, 110, 111, 113, 114, 117,
120, 123, and 125 of the S-1 Registration Statement to clarify the Company’s statements.

 Our Strategy,
page 99

14.
 Given the current state of development of your product candidates, it is unclear if you have a basis
for your statements that you have “industry-leading expertise” (at page 99 and

United States securities and exchange commission logo
July 17, 2020
Nello Mainolfi, Ph.D.
President and Chief Executive Officer
Kymera Therapeutics, Inc.
300 Technology Square, 2nd Floor
Cambridge, MA 02139
Re:Kymera Therapeutics, Inc.
Draft Registration Statement on Form S-1
Submitted June 22, 2020
CIK No. 0001815442
Dear Dr. Mainolfi:
            We have reviewed your draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1
Prospectus Summary
Overview, page 1
1.Define or explain these terms the first time you use them in the document:
•"IL-1R/TLR" and "JAK/STAT" (page 1);
•"E3 ligase" (page 2);
•"hidradenitis suppurativa" (page 3);
•"JAKs" (page 3);
•PK/PD modeling (page 4);
•“cereblon and von Hippel-Lindau, or VHL” (at pages 100, 103); and
•TPD (page 105).

 FirstName LastNameNello Mainolfi, Ph.D.
 Comapany NameKymera Therapeutics, Inc.
 July 17, 2020 Page 2
 FirstName LastNameNello Mainolfi, Ph.D.
Kymera Therapeutics, Inc.
July 17, 2020
Page 2
2.Your pipeline appears to include every in-house development program as well as the
program you have licensed to Vertex.  Please revise the table to include only those
programs that are material to the company.  If you believe that every  program listed is
material, please provide us an analysis explaining your belief.  To the extent the Pegasus
Platform remains in your table, revise the disclosure to correspond to the appropriate
column of development.
3.Please revise your table to include columns showing the various material phases of the
development of your potential products, including, as applicable, discovery, preclinical,
development and the various phases of clinical development.  Also include an arrow
indicating the phase each of your product candidates is in for the various stages of
development for each indicated disease area.
4.You mention in your summary and highlight in the pipeline table that other potential
targets for your KT-474 product, which is the farthest product you have in development,
are atopic dermatitis (AD) and rheumatoid arthritis (RA).  You also state, however, that
your product is not targeting these indications.  As such, revise your summary and
pipeline table to remove these references or provide your analysis of why they are
material and appropriate for disclosure here.
Our IRAK4, IRAKIMiD, and STAT3 Programs, page 3
5.Please revise your statements on pages 3, 125 and elsewhere in the prospectus that certain
of your product candidates are “first-in-class.”  These statements imply an expectation of
regulatory approval and are inappropriate given the length of time and uncertainty with
respect to securing marketing approval.
6.For KT-474 and IRAKIMiD you state you will submit an IND and initiate phase 1 trial in
first half of 2021, and for IRAKIMiD, you state you expect to do both in the second half
of 2021.  As you have more control over when you submit the IND, revise to clarify when
you expect that to occur for each product.
Corporate Information, page 6
7.Please provide us with copies of all written communications, as defined in Rule 405 under
the Securities Act, that you, or anyone authorized to do so on your behalf, present to
potential investors in reliance on Section 5(d) of the Securities Act, whether or not they
retain copies of the communications.
Risk Factors
Risks Related to Intellectual Property, page 43
8.We note the risk factor on page 46 related to objections to the name Kymera and Kymera
Therapeutics.  You disclose that "If we are unable to obtain a registered trademark or
establish name recognition based on our trademarks and trade names, we may not be able
to compete effectively and our business may be adversely affected."  Is it also true that

 FirstName LastNameNello Mainolfi, Ph.D.
 Comapany NameKymera Therapeutics, Inc.
 July 17, 2020 Page 3
 FirstName LastName
Nello Mainolfi, Ph.D.
Kymera Therapeutics, Inc.
July 17, 2020
Page 3
you could be forced to change your name and incur additional significant related
expenses?  Revise the risk factor to further disclose the potential material risks.
9.On page 53, you disclose that "the Leahy-Smith Act has transformed the U.S. patent
system into a “first inventor to file” system. The first-inventor-to-file provisions, however,
only became effective on March 16, 2013. Accordingly, it is not yet clear what, if any,
impact the Leahy-Smith Act will have on the operation of our business."  (Emphasis
Added).  As your company was first incorporated in December 2015, clarify why the Act's
application to you remains unclear.
Use of Proceeds, page 70
10.You state the proceeds will be used for the "advancement" of each of your products.
Please expand your disclosure regarding the proceeds to be used for your product
candidates to describe how far in the development process you estimate the allocated
proceeds from this offering will enable you to reach.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Components of Our Results of Operations, page 83
11.It appears from page F-24 you have a collaboration agreement with an entity other than
Vertex, or a prior, separate collaboration agreement with Vertex.  Revise to disclose that
collaboration or provide your analysis why disclosure is not required.
Critical Accounting Policies and Estimates
Determination of the Fair Value of Common Stock, page 94
12.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 IPO and the estimated offering price. This information will help facilitate our
review of your accounting for equity issuances including stock compensation and
beneficial conversion features.
Business
Overview, page 97
13.Here and on pages 103 and 104 you refer to "potent activity" of your potential degraders,
your "highly efficient, selective and potent degraders" with "appropriate pharmaceutical
properties" and "potent and specific degraders."  Given the stage of your product
development, it appears premature to describe your product candidates as potent, which
implies they are effective.  Please revise or advise why this disclosure is appropriate.

 FirstName LastNameNello Mainolfi, Ph.D.
 Comapany NameKymera Therapeutics, Inc.
 July 17, 2020 Page 4
 FirstName LastName
Nello Mainolfi, Ph.D.
Kymera Therapeutics, Inc.
July 17, 2020
Page 4
Our Strategy, page 99
14.Given the current state of development of your product candidates, it is unclear if you
have a basis for your statements that you have “industry-leading expertise" (at page 99
and 137) and "significant competitive advantages" and “dominant intellectual property
position (at page 137).  Please clarify.
15.Revise Figures 8-10 and 18 to better explain what each depicts.  For Figures 8-9 in
particular, the point of the graphics are unclear beyond reinforcing your product by
association.
16.On page 113, you defined hPMBC.  Then, starting on page 117 and going forward, you
identify the generic word “blood” as PMBC.  Please clarify any distinction.
17.We note the blog and press release on your website related to the findings reported at the
American Association of Cancer Research virtual meeting held June 22, 2020, the date of
this registration statement.  To the extent you have not done so, revise the document to
include material information included on your website.
Collaborations, page 136
18.On your website you list several “Academic Collaborators” including Yale, Columbia,
New York University and the Dana-Farber Cancer Institute, and “Partners,” including
GlaxsoSmithKline, Vertex and the Leukemia & Lymphoma Society.  Only the Vertex
agreement is discussed here.  Advise us of your collaborations or partnerships with these
entities and provide your analysis regarding whether they are required to be disclosed
here.
19.Revise to disclose your collaboration with Sanofi as discussed in your July 9, 2020 press
release.  Avoid use of the term “first-in-class," used in the press release, for the reasons
cited above.
Intellectual Property, page 138
20.Revise the paragraph addressing "Target-Specific Degrader Patent Families" to disclose
the number of patents and their location.  Revise this section to clarify whether you own
or license the patents disclosed, clarify the types of patents you have, and identify the
jurisdictions in which you have foreign patents.  We note some of this disclosure in the
risk factor on page 43.
Facilities, page 156
21.You disclose in the notes of the financial statements that you terminated a lease effective
July 31, 2020.  It appears that is the Cambridge lease, as the lease you have included as an
exhibit extends until May 2023.  You state you “lease and expect to occupy” the property
in Watertown.  Revise your disclosure in this section to clarify your current and expected
facilities.  Refer to Item 102 of Regulation S-K

 FirstName LastNameNello Mainolfi, Ph.D.
 Comapany NameKymera Therapeutics, Inc.
 July 17, 2020 Page 5
 FirstName LastName
Nello Mainolfi, Ph.D.
Kymera Therapeutics, Inc.
July 17, 2020
Page 5
Executive Compensation
Employment Agreements with our Named Executive Officers, page 169
22.File the employment agreements with each of the named executive officers as required by
Item 601(b)(10) of Regulation S-K.
Certain Relationships and Related Party Transactions, page 182
23.File the Vertex Participation Agreement as an exhibit.  Refer to Item 601(b)(10) of
Regulation S-K.
Description of Capital Stock
Choice of Forum, page 193
24.Here you state, that your "choice of forum provision does not apply to any causes of
action arising under the Securities Act or the Exchange Act."  in the risk factor on page
62, however, you state, "The Delaware Forum Provision will not apply to any causes of
action arising under the Securities Act or the Exchange Act," but then state, "the United
States District Court for the District of Massachusetts shall be the sole and exclusive
forum for resolving any complaint asserting a cause of action arising under the Securities
Act," calling that the "Federal Forum Provision."  We note that Section 22 of the
Securities Act creates concurrent jurisdiction for federal and state courts over all suits
brought to enforce any duty or liability created by the Securities Act or the rules and
Regulations thereunder, and Section 27 of the Exchange Act creates exclusive federal
jurisdiction over all suits brought to enforce any duty or liability created by the Exchange
Act or the rules and regulations thereunder.  Clarify whether there are forum restrictions
for Exchange Act claims.
            You may contact Vanessa Robertson at (202) 551-3649 or Daniel Gordon at (202) 551-
3486 if you have questions regarding comments on the financial statements and related
matters.  Please contact Abby Adams at (202) 551-6902 or Celeste Murphy at (202) 551-
3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences