SecProbe.io

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 J.P. Galda & Co.

 40 East Montgomery Avenue, LTW 220

 Ardmore, Pennsylvania 19008

 May 23, 2025

 VIA EDGAR AND E-MAIL

 Mr. Alan Campbell

 Mr. Joseph McCann

 Office of Life Sciences

 Division of Corporate Finance

 U.S. Securities and Exchange Commission

 100 F. Street, N.E.

 Washington, DC 20549-7010

 Re: Revelation Biosciences, Inc. Registration Statement on Form S-1

 Commission File No. 333-287423

 Gentlemen:

 This letter will confirm my conversation with Mr. McCann to the effect
that we are not individually responding to the Staff's letter of comments on the above-captioned Registration Statement because
the transaction has been restructured to eliminate the zero exercise price warrants and the Class H-3 Common Stock Warrants, thereby rendering
such comments no longer applicable.

 Very truly yours,

 /s/ Joseph P. Galda

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 1
 filename1.htm

 REVELATION
BIOSCIENCES, INC.

 4660
La Jolla Village Drive, Suite 100

 San
Diego, CA 92122

 May
22, 2025

 VIA
EDGAR AND E-MAIL

 Mr.
Alan Campbell

 Office
of Life Sciences

 Division
of Corporate Finance

 U.S.
Securities and Exchange Commission

 100
F. Street, N.E.

 Washington,
DC 20549-7010

 Re:
Revelation Biosciences, Inc. Registration Statement on Form S-1;

 Commission
File No. 333-287423

 Dear
Mr. Campbell:

 Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, Revelation Biosciences Inc. (the "Company") hereby
requests that the effectiveness of the Company's Registration Statement on Form S-1 (File No. 333-287423) be accelerated by the
U.S. Securities and Exchange Commission to 5:00 p.m. Eastern Time on Tuesday, May 27, 2025, or as soon thereafter is practicable.

 The
Company hereby authorizes Joseph P. Galda of J.P. Galda & Co. to orally modify or withdraw this request for acceleration. Please
contact Mr. Galda at (215) 815-1534 with any questions you may have concerning this request, and please notify him when this request
for acceleration has been granted.

 Thank
you for your courtesy and cooperation in this matter.

 Very
truly yours,

 REVELATION
BIOSCIENCES, INC.

 By: /s/
 Chester S. Zygmont, III

 Chester
 S. Zygmont, III, CFO

CORRESP
 1
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 REVELATION
BIOSCIENCES, INC.

 4660
La Jolla Village Drive, Suite 100

 San
Diego, CA 92122

 May
22, 2025

 VIA
EDGAR AND E-MAIL

 Mr.
Alan Campbell

 Office
of Life Sciences

 Division
of Corporate Finance

 U.S.
Securities and Exchange Commission

 100
F. Street, N.E.

 Washington,
DC 20549-7010

 Re:
Revelation Biosciences Inc. Registration Statement on Form S-1;

 Commission
File No. 333-287423

 Dear Mr. Campbell:

 In accordance with your discussion with our counsel, we are withdrawing
our acceleration request for effectiveness of the above-captioned Registration Statement dated May 20, 2025, seeking effectiveness today
at 5:00 p.m. We will be submitting a new request later today seeking an effective date on Tuesday next week.

 Thank you for your courtesy and cooperation in this matter.

 Very truly yours,

 REVELATION BIOSCIENCES, INC.

 By: /s/
 Chester S. Zygmont, III

 Chester
 S. Zygmont, III, CFO

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 21, 2025

James Rolke
Chief Executive Officer
Revelation Biosciences, Inc.
4660 La Jolla Village Drive, Suite 100
San Diego, CA 92122

 Re: Revelation Biosciences, Inc.
 Registration Statement on Form S-1
 Filed May 20, 2025
 File No. 333-287423
Dear James Rolke:

 We have conducted a limited review of your 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.

Registration Statement on Form S-1
Cover Page

1. We note your disclosure indicating that under the "zero exercise price"
option, holders
 of your Class H-1 Warrants will have the right to receive an aggregate
of 32,786,880
 shares of your common stock based on the formula provided. Please revise
the cover
 page header to highlight the maximum number of shares that could be
issued upon
 exercise of your Class H-1 Warrants. For guidance, refer to Regulation
S-K, Item
 501(b)(2). Please similarly revise your Summary of the Offering section.
2. Please revise your cover page disclosure to briefly describe the
event(s) that would
 trigger the automatic exercise of the Class H-3 Warrants and any
provisions that
 would preclude automatic exercise.
 May 21, 2025
Page 2
Summary of the Offering
Use of Proceeds, page 4

3. Please review your Use of Proceeds disclosure here and on page 44 to
clarify that if
 the Stockholder Approval is not obtained or another event precludes the
automatic
 exercise of the Class H-3 Warrants, your proceeds from the offering will
be
 significantly reduced.
Risk Factors
Risks Related to this Offering, page 7

4. Please revise this subsection to include a risk factor disclosing that
dilution from the
 offering could cause the company s common stock price to fall below
Nasdaq's
 minimum bid price, which could result in its shares being delisted from
Nasdaq. If the
 registrant has plans to seek shareholder approval for a reverse stock
split, such plans
 should be disclosed in the registration statement, including the
proposed ratio, if
 known. In your new risk factor, please also discuss Nasdaq's recent
actions taken
 pursuant to Listing Rule 5101 with respect to other companies that have
consummated
 offerings involving zero exercise price warrants, or advise.

 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.

 Please contact Alan Campbell at 202-551-4224 or Joe McCann at
202-551-6262 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: J.P. Galda, Esq.
</TEXT>
</DOCUMENT>

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 REVELATION BIOSCIENCES, INC.

 4660 La Jolla Village Drive, Suite 100

 San Diego, CA 92122

 May 20, 2025

 VIA EDGAR AND E-MAIL

 Mr. Allan Campbell

 Office of Life Sciences

 Division of Corporate Finance

 U.S. Securities and Exchange Commission

 100 F. Street, N.E.

 Washington, DC 20549-7010

 Re: Revelation Biosciences Inc. Registration Statement on
Form S-1;

 Commission File No. 333-287423

 Dear Mr.Campbell:

 Pursuant to Rule 461 promulgated under the Securities Act of 1933,
as amended, Revelation Biosciences Inc. (the "Company") hereby requests that the effectiveness of the Company's Registration
Statement on Form S-1 (File No. 333-287423) be accelerated by the U.S. Securities and Exchange Commission to 5:00 p.m. Eastern Time
on Thursday, May 22, 2025, or as soon thereafter is practicable.

 The Company hereby authorizes Joseph P. Galda of J.P. Galda & Co.
to orally modify or withdraw this request for acceleration. Please contact Mr. Galda at (215) 815-1534 with any questions you may have
concerning this request, and please notify him when this request for acceleration has been granted.

 Thank you for your courtesy and cooperation in this matter.

 Very truly yours,

 REVELATION BIOSCIENCES, INC.

 By: /s/ Chester S. Zygmont, III

 Chester S. Zygmont, III, CFO

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 9, 2025

James Rolke
Chief Executive Officer
Revelation Biosciences, Inc.
4660 La Jolla Village Drive, Suite 100
San Diego, CA 92122

 Re: Revelation Biosciences, Inc.
 Draft Registration Statement on Form S-1
 Submitted April 4, 2025
 CIK No. 0001810560
Dear James Rolke:

 This is to advise you that we do not intend to review your registration
statement.

 We request that you publicly file your registration statement at least
two business
days 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 Alan Campbell at 202-551-4224 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: J.P. Galda, Esq.
</TEXT>
</DOCUMENT>

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  CORRESP

  Revelation Biosciences, Inc.

  4660 La Jolla Village Drive, Suite 100

  San Diego, California 92122

    December 20, 2024

  Via EDGAR

  Securities and Exchange Commission

  100 F Street, NE

  Washington, DC 20549

    Attention:

    Chris Edwards

    Re:

    Revelation Biosciences, Inc.

    Registration Statement on Form S-3

    Commission File No. 333-283764

  Mr. Edwards:

  On behalf of Revelation Biosciences, Inc. (the “Company”), I hereby request that the Commission declare effective the above-captioned registration statement at 5:00pm on December 20, 2024, or as soon thereafter as practicable. Please call or email our counsel, J.P. Galda, with any further questions or comments.

    Very truly yours,

    Revelation Biosciences, Inc.

    /s/ Chester S. Zygmont, III

    Chief Financial Officer

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  CORRESP

  Revelation Biosciences, Inc.

  4660 La Jolla Village Drive, Suite 100

  San Diego, California 92122

    December 19, 2024

  Via EDGAR

  Securities and Exchange Commission

  100 F Street, NE

  Washington, DC 20549

    Attention:

    Chris Edwards

    Re:

    Revelation Biosciences, Inc.

    Registration Statement on Form S-3

    Commission File No. 333-283764

  Mr. Edwards:

  On behalf of Revelation Biosciences, Inc. (the “Company”), I hereby request that the Commission declare effective the above-captioned registration statement at 5:00pm on December 23, 2024, or as soon thereafter as practicable. Please call or email our counsel, J.P. Galda, with any further questions or comments.

    Very truly yours,

    Revelation Biosciences, Inc.

    /s/ Chester S. Zygmont, III

    Chief Financial Officer

December 18, 2024
James Rolke
Chief Executive Officer
Revelation Biosciences, Inc.
4660 La Jolla Village Drive, Suite 100
San Diego, California 92122
Re:Revelation Biosciences, Inc.
Registration Statement on Form S-3
Filed December 12, 2024
File No. 333-283764
Dear James Rolke:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            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 Chris Edwards at 202-551-6761 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Joseph P. Galda

September 25, 2024
Chester S. Zygmont, III
Chief Financial Officer
Revelation Biosciences, Inc.
4660 La Jolla Village Drive
Suite 100
San Diego, CA 92122
Re:Revelation Biosciences, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
Filed March 22, 2024
File No. 001-39603
Dear Chester S. Zygmont III:
            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

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  CORRESP

   J.P. Galda & Co.

  Attorneys-at-Law

  40 E Montgomery Avenue, LTW 220

  Ardmore, Pennsylvania 19003

  Telephone (215) 815-1534

    September 23, 2024

  Via Email and EDGAR

  Office of Life Sciences

  Division of Corporation Finance

  Securities and Exchange Commission

  100 F Street, NE

  Washington, DC 20549

    Attention:

    Gary Newberry

Angela Connell

    Re:

    Revelation Biosciences, Inc.

    Form 10-K for the Fiscal Year Ended December 31, 2023

    Filed March 22, 2024

    File No. 001-39603

  Mr. Newberry and Ms. Connell:

  This letter is submitted on behalf of Revelation Biosciences, Inc. (the “Company”) in response to comments of the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) with respect to the Company’s annual report on Form 10-K for the fiscal year ended December 31, 2023, filed on March 22, 2024 (the “10-K”) as set forth in the Staff’s letter dated September 13, 2024 to Chester S. Zygmont III, Chief Financial Officer of the Company (the “Comment Letter”). The Company is concurrently filing its Amendment No. 1 to the 10-K, which include changes to reflect responses to the Staff’s comments and other updates.

  For reference purposes, the text of the Comment Letter has been reproduced and italicized herein with responses below each numbered comment. The responses provided herein are based upon information provided to J.P. Galda & Co by the Company.

  Form 10-K for the Fiscal Year Ended December 31, 2023

  Exhibits

    1.

    We note that the certifications provided as Exhibits 31.1 and 31.2 do not include paragraph 4(b) and the introductory language in paragraph 4 referring to your internal control over financial reporting. Please amend your filing to provide revised certifications as well as full Item 9A disclosures and financial statements. Refer to Question 246.13 of the Regulation S-K Compliance & Disclosure Interpretations for guidance. Please also make conforming changes in all of your future periodic filings.

  Response: The Company acknowledges the Staff’s comment and has revised its disclosure by filing Amendment No. 1 to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2023 (the “Form 10-K/A”) to include revised certifications in Exhibits 31.1 and 31.2 to include paragraph 4(b) and the introductory language in paragraph 4 that refers to internal control over financial reporting pursuant to Item 601(b)(31)(i) of Regulation S-K. In accordance with 246.13 of the Securities and Exchange Commission’s Compliance and Discussion Interpretations on Regulation S-K and the Staff’s comment, the Form 10-K/A includes Item 8. Financial Statements and Supplementary Data, Item 9A. Controls and Procedures and the Sections 302 and 906 certifications. The Company has also amended it’s Quarterly Report on Form 10-Q for the three months ended March 31, 2024 and three and six months June 30, 2024 in a similar manner.

    Very truly yours,

    J.P. Galda & Co.

    /s/ J.P. Galda & Co.

  cc: Mr. Chester S. Zygmont, III

        Ms. Kelly Mayo

September 13, 2024
Chester S. Zygmont, III
Chief Financial Officer
Revelation Biosciences, Inc.
4660 La Jolla Village Drive
Suite 100
San Diego, CA 92122
Re:Revelation Biosciences, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
Filed March 22, 2024
File No. 001-39603
Dear Chester S. Zygmont III:
            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 the Fiscal Year Ended December 31, 2023
Exhibits
1.We note that the certifications provided as Exhibits 31.1 and 31.2 do not include
paragraph 4(b) and the introductory language in paragraph 4 referring to your internal
control over financial reporting. Please amend your filing to provide revised
certifications as well as full Item 9A disclosures and financial statements. Refer to
Question 246.13 of the Regulation S-K Compliance & Disclosure Interpretations for
guidance. Please also make conforming changes in all of your future periodic filings.

            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.

September 13, 2024
Page 2
            Please contact Gary Newberry at 202-551-3761 or Angela Connell at 202-551-3426 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences

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  CORRESP

  Revelation Biosciences, Inc.

  4660 La Jolla Village Drive, Suite 100

  San Diego, California 92122

    September 10, 2024

  Via EDGAR

  Securities and Exchange Commission

  100 F Street, NE

  Washington, DC 20549

    Attention:

    Chris Edwards

    Re:

    Revelation Biosciences, Inc.

    Registration Statement on Form S-3

    Commission File No. 333-281909

  Mr. Edwards:

  On behalf of Revelation Biosciences, Inc. (the “Company”), I hereby request that the Commission declare effective the above-captioned registration statement at 5:00pm on September 12, 2024, or as soon thereafter as practicable. Please call or email our counsel, J.P. Galda, with any further questions or comments.

    Very truly yours,

    Revelation Biosciences, Inc.

    /s/ Chester S. Zygmont, III

    Chief Financial Officer

September 9, 2024
James Rolke
Chief Executive Officer
Revelation Biosciences, Inc.
4660 La Jolla Village Drive, Suite 100
San Diego, CA 92122
Re:Revelation Biosciences, Inc.
Registration Statement on Form S-3
Filed September 3, 2024
File No. 333-281909
Dear James Rolke:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            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 Tyler Howes at 202-551-3370 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Joseph P. Galda, Esq.

July 23, 2024
James Rolke
Chief Executive Officer
Revelation Biosciences, Inc.
4660 La Jolla Village Drive, Suite 100
San Diego, California 92122
Re:Revelation Biosciences, Inc.
Registration Statement on Form S-3
Filed July 19, 2024
File No. 333-280908
Dear James Rolke:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            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 Chris Edwards at 202-551-6761 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Joseph P. Galda

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  CORRESP

  Revelation Biosciences, Inc.

  4660 La Jolla Village Drive, Suite 100

  San Diego, California 92122

    July 26, 2024

  Via EDGAR

  Securities and Exchange Commission

  100 F Street, NE

  Washington, DC 20549

    Attention:

    Chris Edwards

    Re:

    Revelation Biosciences, Inc.

    Registration Statement on Form S-3

    Commission File No. 333-280908

  Mr. Edwards:

  On behalf of Revelation Biosciences, Inc. (the “Company”), I hereby request that the Commission declare effective the above-captioned registration statement at 5:00pm on July 26, 2024, or as soon thereafter as practicable. Please call or email our counsel, J.P. Galda, with any further questions or comments.

    Very truly yours,

    Revelation Biosciences, Inc.

    /s/ Chester S. Zygmont, III

    Chief Financial Officer

CORRESP
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Revelation Biosciences, Inc.

4660 La Jolla Village Drive

San Diego, California 92122

    January 30, 2024

Via EDGAR

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

    Attention:
    Cindy Polynice

    Laura Crotty

    Re:
    Revelation Biosciences, Inc.

    Registration Statement on Form S-1

    Commission File No. 333-276232

Mesdames Polynice and Crotty:

On behalf of Revelation Biosciences, Inc. (the “Company”),
I hereby request that the Commission declare effective the above-captioned registration statement at 5:15pm on January 31, 2024, or as
soon thereafter as practicable. Please call or email our counsel, J.P. Galda, with any further questions or comments.

    Very truly yours,

    Revelation Biosciences, Inc.

    /s/
    Chester S. Zygmont, III

    Chief Financial Officer

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J.P. Galda & Co.

Attorneys-at-Law

40 Montgomery Avenue, LTW 220

Ardmore, Pennsylvania 19003

Telephone (215) 815-1534

January 29, 2024

Via EDGAR

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

    Attention:
    Cindy Polynice

    Laura Crotty

Re: Revelation Biosciences, Inc.

Registration Statement on Form S-1

File Number 333-276232

Mesdames Polynice and Crotty:

Today Revelation Biosciences, Inc. (the “Company”)
has filed Amendment No. 1 to its Registration Statement on Form S-1 to respond to the staff's letter of comments dated January 2, 2024
(the “Comment Letter”), to reflect the effects of a 1 for 30 reverse stock split which was effective as of January 25, 2024,
and to include the number of warrants and prefunded warrants to be registered. The numbered paragraphs below correspond to the numbered
comments in the Comment Letter.

 1. The cover page has been revised to state the date on which the offering will be terminated (25 days after the effective date of the
registration statement).

 2. The number of warrants and prefunded warrants (as well as the number of shares of common stock underlying the warrants and the pre-funded
warrants) has been completed.

As I discussed on the telephone with Ms. Polynice,
the Company will be requesting acceleration of effectiveness as soon as the Staff confirms that there are no further comments.

Please call or email with any further questions or
comments.

Very truly yours,

/s/ Joseph P. Galda

United States securities and exchange commission logo
January 2, 2024
James Rolke
Chief Executive Officer
Revelation Biosciences, Inc.
4660 La Jolla Village Drive, Suite 100
San Diego, California 92122
Re:Revelation Biosciences, Inc.
Registration Statement on Form S-1
Filed December 22, 2023
File No. 333-276232
Dear James Rolke:
            We have conducted a limited review of your 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.
Registration Statement on Form S-1 filed December 22, 2023
Cover Page
1.Please revise your cover page to disclose a set date the offering will end. Refer to Item
501(b)(8)(iii) of Regulation S-K for guidance.
2.Please revise the heading on your cover page to quantify the number of warrants and
prefunded warrants to be registered.
            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.

 FirstName LastNameJames Rolke
 Comapany NameRevelation Biosciences, Inc.
 January 2, 2024 Page 2
 FirstName LastName
James Rolke
Revelation Biosciences, Inc.
January 2, 2024
Page 2
            Please contact Cindy Polynice at 202-551-8707 or Laura Crotty at 202-551-7614 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joseph Galda, Esq.

CORRESP
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Revelation Biosciences, Inc.

4660 La Jolla Village Drive

San Diego, California 92122

    February 6, 2023

Via EDGAR

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

  Attention:

  Daniel Crawford

  Joe McCann

    Re:
    Revelation Biosciences, Inc.

    Registration Statement on Form S-1

    Commission File No. 333-268576

Messrs. Crawford and McCann:

On behalf of Revelation Biosciences, Inc. (the “Company”),
I hereby request that the Commission declare effective the above-captioned registration statement at 5:00pm on February 8, 2023, or as
soon thereafter as practicable. Please call or email our counsel, J.P. Galda, with any further questions or comments.

  Very truly yours,

  Revelation Biosciences, Inc.

  /s/
   Chester S. Zygmont, III

  Chief
    Financial Officer

CORRESP
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J.P. Galda & Co.

Attorneys-at-Law

40 Montgomery Avenue, LTW 220

Ardmore, Pennsylvania 19003

Telephone (215) 815-1534

February 1, 2023

Via Email and EDGAR

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: 	Daniel Crawford

	Joe McCann

Re: Revelation Biosciences, Inc.

Registration Statement on Form S-1

Commission File Nos. 333-268076, 268576

Gentlemen:

Revelation Biosciences, Inc. (the “Company”) today has
filed an amendment (the “Amendment”) to the above-captioned registration statements on Form S-1 as we discussed last week.
The amendment updates the executive compensation disclosure, provides a business update and includes a new exchange feature for the warrants
suggested by the Placement Agent. Most importantly, it reflects the authorization of additional shares of common stock to remove the exercise
contingency for the offered warrants in accordance with the Staff’s oral comment.

Following discussion with Roth Capital Partners, subject to the
timing of the Staff’s review, it would be the Company's plan to go effective on February 8, 2023 at the close of business, with
pricing immediately thereafter, orders finalized the next day, and closing presumably on February 13, 2023. Please let us know if this
is a timetable that you think you can work with.

As usual, the Company contact is Chester S, Zygmont, III, the Company's
chief financial officer, whose e-mail is czygmont@revbiosciences.com. As always, thanks for your assistance.

Kind regards,

/s/ Joseph P. Galda

CORRESP
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Revelation Biosciences, Inc.

4660 La Jolla Village Drive

San Diego, California 92122

    November 17, 2022

Via EDGAR

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Office of Life Sciences

Re: Revelation Biosciences, Inc.

Registration Statement on Form S-1

Commission File No. 333-268076

Ladies and Gentlemen:

On behalf of Revelation Biosciences, Inc., I hereby request that the Commission
declare effective the above-captioned registration statement at 4:00pm on November 18, 2022, or as soon thereafter as practicable. Please
call or email our counsel, J.P. Galda, with any further questions or comments.

    Very truly yours,

    Revelation Biosciences, Inc.

    /s/ Chester S. Zygmont, III

    Chief
    Financial Officer

United States securities and exchange commission logo
November 14, 2022
James Rolke
Chief Executive Officer
Revelation Biosciences, Inc.
4660 La Jolla Village Drive, Suite 100
San Diego, California 92122
Re:Revelation Biosciences, Inc.
Registration Statement on Form S-1
Filed October 31, 2022
File No. 333-268076
Dear James Rolke:
            We have limited our review of your registration statement to those issues we have
addressed in our 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 filed October 31, 2022
Cover Page
1.We note your disclosure here that you have engaged Roth Capital Partners, LLC as your
exclusive placement in a best efforts offering. Please revise your cover page to disclose
the termination date of this offering or otherwise advise. See Item 501(b)(8) of Regulation
S-K.
2.We note your disclosure that you expect to deliver your shares, Class C Common Stock
Warrants and pre-funded warrants to purchasers in the offering on or about an as yet to be
determined date in 2022. Given that this is language typically included in a firm
commitment underwritten offering and you have indicated this is a best efforts offering,
please advise us of the reason for this disclosure.

 FirstName LastNameJames Rolke
 Comapany NameRevelation Biosciences, Inc.
 November 14, 2022 Page 2
 FirstName LastName
James Rolke
Revelation Biosciences, Inc.
November 14, 2022
Page 2
Exhibits
3. With reference to Item 601(b)(1) of Regulation S-K, please file your Placement
Agency Agreement.
            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.
            Please contact Daniel Crawford at 202-551-7767 or Joe McCann at 202-551-6262 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joseph Galda, Esq.

CORRESP
1
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Revelation Biosciences, Inc.

4660 La Jolla Village Drive

San Diego, California 92122

July
25, 2022

Via EDGAR

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: Ms. Abby Adams

Office of Life Sciences

Re: Revelation Biosciences, Inc.

Registration Statement on Form S-1

Commission File No. 333-266108

Ms. Adams:

On behalf of Revelation Biosciences, Inc. (the “Company”),
I hereby request that the Commission declare effective the above-captioned registration statement at 5:00pm on July 25, 2022, or as soon
thereafter as practicable. Please call or email our counsel, J.P. Galda, with any further questions or comments.

    Very truly yours,

    Revelation Biosciences, Inc.

    /s/ Chester S. Zygmont, III

    Chief
    Financial Officer

United States securities and exchange commission logo
July 18, 2022
Chester S. Zygmont, III
Chief Financial Officer
Revelation Biosciences, Inc.
4660La Jolla Village Drive, Suite 100
San Diego, California 9222
Re:Revelation Biosciences, Inc.
Registration Statement on Form S-1
Filed July 13, 2022
File No. 333-266108
Dear Mr. Zygmont:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            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 Abby Adams at (202) 551-6902 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joseph P. Galda, Esq.

CORRESP
1
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Revelation Biosciences, Inc.

4660 La Jolla Village Drive

San Diego, California 92122

    June 7, 2022

Via EDGAR

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: Chris Edwards

Office of Life Sciences

Re: Revelation Biosciences, Inc.

Registration Statement on Form S-1

Commission File No. 333-265326

Mr. Edwards:

On behalf of Revelation Biosciences, Inc. (the “Company”),
I hereby request that the Commission declare effective the above-captioned registration statement at 4:00pm on June 10, 2022, or as soon
thereafter as practicable. Please call or email our counsel, J.P. Galda, with any further questions or comments.

    Very truly yours,

    Revelation Biosciences, Inc.

    /s/ Chester S. Zygmont, III

      Chief Financial Officer

United States securities and exchange commission logo
June 6, 2022
James Rolke
Chief Executive Officer
Revelation Biosciences, Inc.
4660 La Jolla Village Drive, Suite 100
San Diego, California 92122
Re:Revelation Biosciences, Inc.
Registration Statement on Form S-1
Filed May 31, 2022
File No. 333-265326
Dear Mr. Rolke:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            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 Chris Edwards at 202-551-6761 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       J.P. Galda, Esq.

CORRESP
1
filename1.htm

Revelation Biosciences, Inc.

4660 La Jolla Village Drive

San Diego, California 92122

  February 3, 2022

Via EDGAR

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: Michael Davis

Special Counsel

Office of Life Sciences

Re: Revelation Biosciences, Inc.

Registration Statement on Form S-1

Commission File No. 333-262410

Mr. Davis:

On behalf of Revelation Biosciences, Inc. (the “Company”),
I hereby request that the Commission declare effective the above-captioned registration statement at 4:00pm on February 7, 2022, or as
soon thereafter as practicable. Please call or email our counsel, J.P. Galda, with any further questions or comments.

  Very
truly yours,

Revelation
Biosciences, Inc.

/s/
Chester S. Zygmont, III

      Chief
Financial Officer

CORRESP
1
filename1.htm

J.P. Galda & Co.

Attorneys-at-Law

40 East Montgomery Avenue, LTW 200

Ardmore, PA 19003

Telephone (215) 815-1534

  February 3, 2022

Via EDGAR

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention: Michael Davis

Special Counsel

Office of Life Sciences

Re: Revelation Biosciences, Inc.

Registration Statement on Form S-1

Commission File No. 333-262410

Mr. Davis:

On behalf of Revelation Biosciences, Inc. (the “Company”),
I hereby request that the Commission declare effective the above-captioned registration statement at 4:00pm on February 7, 2022, or as
soon thereafter as practicable. Please call or email with any further questions or comments.

  J.P.
Galda & Co.

  /s/
J.P. Galda

United States securities and exchange commission logo
February 2, 2022
James Rolke
Chief Executive Officer
Revelation Biosciences, Inc.
4660 La Jolla Village Drive, Suite 100
San Diego, California 92122
Re:Revelation Biosciences, Inc.
Registration Statement on Form S-1
Filed January 28, 2022
File No. 333-262410
Dear Mr. Rolke:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            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 Michael Davis at 202-551-4385 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Joseph P. Galda, Esq.

CORRESP
1
filename1.htm

J.P.
Galda & Co.

Attorneys-at-Law

40
East Montgomery Avenue, LTW 220

Ardmore,
Pennsylvania 19003

Telephone
(215) 815-1534

January
28, 2022

Via
Edgar

Securities
and Exchange Commission

100
F Street, NE

Washington,
DC 20549

Re:
Revelation Biosciences, Inc.

Ladies
and Gentlemen:

Today
Revelation Biosciences, Inc. is filing a selling securityholder Registration Statement pursuant to registration rights granted to the
purchaser in a recently completed PIPE transaction. The Company has recently completed a de-SPAC transaction in which the disclosure
regarding the Company received a full review. The only changes to the disclosure relate to the change in form, the PIPE transaction description,
and to reflect the impact of the de-SPAC transaction. As a result, we would like to become effective prior to the financial statements
becoming stale in mid-February.

Correspondence
should be directed to:

Chester
S. Zygmont, III (principal issuer contact)

Chief
Financial Officer

4660
La Jolla Village Drive, Suite 100

San
Diego, California 92122

Mobile
Phone: 650-272-7018

Email:
czygmont@revbiosciences.com

Joseph
P. Galda, Esq. (counsel to the issuer)

J.P.
Galda & Co.

40
East Montgomery Avenue, LTW 220

Ardmore,
Pennsylvania 19003

Mobile
Phone: 215-815-1534

Email:
jpgalda@jpgaldaco.com

Please
contact the undersigned with any questions or comments.

  Very truly yours,

  J.P. Galda & Co.

  By: /s/ Joseph P. Galda

CORRESP
1
filename1.htm

Petra Acquisition, Inc.

5 West
21st Street

New York, NY 10010

Tel: (971) 622-5800

December 14, 2021

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Alan Campbell and Joe McCann

    Re:
    Petra Acquisition, Inc.

    Registration Statement on Form S-4

    Filed September 20, 2021, as amended

    File No. 333-259638

Dear Mr. Campbell and Mr. McCann:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, the
registrant Petra Acquisition Inc. hereby requests acceleration of effectiveness of the above referenced Registration Statement so that
it will become effective at 4:00 p.m. ET on Thursday, December 16, 2021, or as soon as practicable thereafter.

Very truly yours,

PETRA ACQUISITION, INC..

/s/ Andreas Typlados

Andreas Typaldos

Chief Executive Officer

    cc:
    Loeb & Loeb LLP

    Mitchell Nussbaum

    Alex Weniger-Araujo

CORRESP
1
filename1.htm

    345
                                            Park Avenue

    New
    York, NY 10154-1895

    Main
    212.407.4000

    Fax 212.407.4990

    www.loeb.com

December 6, 2021

Via
EDGAR

Division
of Corporation Finance

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

    Attn:
    Alan
    Campbell

Joe
McCann

    Re:
    Petra
    Acquisition Inc.

Amendment
No. 1 to Registration

Statement
on Form S-4

Filed
November 4, 2021

File
No. 333-259638

Dear
Mr. Campbell and Mr. McCann:

On
behalf of Petra Acquisition Inc. (the “Company”), we are hereby responding to the letter dated November 26,
2021 (the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange
Commission, regarding the Company’s Amendment No. 1 to Registration Statement on Form S-4, File No. 333-259638 (“Registration
Statement”). In response to the Comment Letter and to update certain information in the Registration Statement, the Company
is filing Amendment No. 2 to the Registration Statement (the “Amended Registration Statement”) with the Commission
today.

For
ease of reference, the text of the Staff’s comment is included in bold-face type below, followed by the Company’s response.

Amendment
No. 1 to Registration Statement on Form S-4 Cover Page

1. We
                                            note your response to prior comment 1. Please revise your cover page to disclose the ownership
                                            percentages of the Sponsor and Insiders, the Public Stockholders and the existing holders
                                            of Revelation’s stock in the combined company.

RESPONSE: The Company acknowledges the Staff’s
comment and has revised the cover page to add the requested ownership percentages.

Q.
Did the Board obtain a third-party valuation or fairness opinion in determining whether or not to proceed with the Business Combination?,
page 8

2. Please
                                            revise to address the following:

 ● Clarify
                                            that the Petra Board approved the business combination agreement prior to receipt of the
                                            fairness opinion.

 ● Quantify
                                            the deferred underwriting, Business Combination, and other fees payable to LifeSci Capital
                                            upon merger consummation.

 ● Disclose
                                            LifeSci’s ownership stake in Revelation.

In
addition, add a separate Question and Answer immediately following the existing one to highlight and explain that LifeSci negotiated
the terms of the business combination agreement on behalf of Petra notwithstanding interests different from or in addition to those held
by other Petra stockholders. With reference to the disclosure on page 107, the Q&A should explain that LifeSci negotiated with Revelation
concerning the amount of LifeSci’s deferred underwriting fee at the same time that LifeSci and Revelation were negotiating Revelation’s
valuation for purposes of determining how much equity would be allocated to the parties in the business combination.

RESPONSE: The Company acknowledges the Staff’s
comment and has revised page 8 to add the requested date clarification, fees and ownership stake. Two new Q&As have also been added.

    Page 2

Summary
of the Proxy Statement/Prospectus

Petra’s
Reasons for the Business Combination, page 21

3. We
                                            note your response to prior comment 10 and re-issue. The risks described beginning on page
                                            22 are primarily risks related to the business combination process and COVID-19 and are not
                                            risks or uncertainties that are specific to Revelation and its business. Based on your response
                                            letter and in particular your statement that the risks related to Revelation that Petra’s
                                            board of directors considered are set forth beginning on page 22 of the document, it appears
                                            that Petra’s board of directors did not consider risks unique to Revelation and its
                                            business in making its decision to approve the Business Combination. Accordingly, please
                                            revise your disclosure here and on page 110 to clarify, if true, that Petra’s board
                                            of directors did not evaluate risks that were specific and unique to Revelation in making
                                            its decision to approve the Business Combination.

Please
also revise your disclosure here and on page 110 to disclose the material risks to unaffiliated investors presented by taking the company
public through a merger rather than an underwritten offering.

RESPONSE: The Company acknowledges the Staff’s
comment and has revised pages 23 and 119 to set forth the risks and uncertainties that are specific to Revelation and its business that
Petra considered in evaluating Revelation as a merger candidate.

4. We
                                            note your statements here and pages 109 and 152 indicating that data from REVDx- 501 correlate
                                            well with PCR for SARS-CoV-2. Please revise to reflect your disclosure on page 169 which
                                            indicates that REVDx-501 returned numerous positive tests from test samples that were PCR
                                            negative.

RESPONSE: The Company acknowledges the Staff’s
comment and has revised page 22, 118, 156, 157 and 173 to show the 86% negative agreement for no replicating SARS-COV-2 virus.

Revelation’s
Reasons for the Business Combination, page 23

5. We
                                            note your response to prior comment 7. Please revise your disclosure in this section to clarify,
                                            if true, that the pro forma enterprise value of approximately $128M considered by Revelation
                                            excluded pro forma cash, including any funds from the trust account.

RESPONSE: The Company acknowledges the Staff’s
comment and has revised page 25 with the requested clarifications regarding the pro forma enterprise value.

6. Please
                                            revise here and in the Background of the Business Combination section to explain why Revelation
                                            discontinued its pursuit of the initial public offering in favor of a business combination
                                            with a SPAC entity, particularly given your disclosures that Revelation received preliminary
                                            indications of interest from new institutional investors at valuations ranging from $120
                                            million to $150 million. Also, revise to clarify what type of initial public offering was
                                            pursued (e.g., firm commitment, best efforts, etc.).

RESPONSE: The Company acknowledges the Staff’s
comment and has revised pages 25 and 115 to explain why Revelation discontinued its pursuit of a firm commitment initial public offering.

    Page 3

Risk
Factors

The
Proposed Charter provides..., page 69

7. Please
                                            revise this risk factor to reflect your disclosure elsewhere in the proxy statement/prospectus
                                            that your Delaware exclusive forum provision will not apply to suits brought to enforce a
                                            duty or liability arising under the Exchange Act or any other claim for which the federal
                                            courts have exclusive jurisdiction. Please also revise to reflect your discussion elsewhere
                                            in the proxy statement/prospectus that Section 22 of the Securities Act creates concurrent
                                            jurisdiction for state and federal courts over all actions brought to enforce any duty or
                                            liability created by the Securities Act or the rules and regulations thereunder. Additionally,
                                            please revise to address any risks and impact on investors, such as increased costs to bring
                                            a claim and that that these provisions can discourage claims or limit inventors’ ability
                                            to bring a claim in a judicial forum that they find favorable.

RESPONSE: The Company acknowledges the Staff’s
comment and has revised the disclosure beginning on page 71 and 220 to address the Staff’s comment.

Unaudited
Pro Forma Combined Condensed Financial Inormation Unaudited Pro

Forma
Combined Condensed Balance Sheet, page 94

8. Please
                                            revise the adjustments in Notes (C) and (D) in the unaudited pro forma combined balance sheet
                                            since the adjustments do not appear to be included in the correct line based on the explanation
                                            in the Notes.

RESPONSE: The Company acknowledges the Staff’s
comment and has switched the order of the two line items in question, which had been out of order, and which should resolve the Staff's
comment.

Background
of the Business Combination, page 104

9. With
                                            reference to the May 17 entry, please identify the Petra board members who were informed
                                            of the potential conflicts of interest. With reference to your disclosure on page 110 indicating
                                            that Petra directors reviewed and considered LifeSci’s interests “during the
                                            negotiations,” discuss how the Petra Board, or the informed board members, reviewed
                                            these interests and what measures, if any, they considered to mitigate the potential impacts
                                            that LifeSci’s conflicts could have on future negotiations. In particular, specifically
                                            discuss whether the Board considered discontinuing LifeSci’s involvement in the merger
                                            negotiations.

RESPONSE: The Company acknowledges the Staff’s
comment and has revised page 114 to address the Staff’s comments.

    Page 4

Opinion
of the Petra Financial Advisor, page 110

10. We
                                            note your response to prior comment 22 and your statement that Scalar did not rely on financial
                                            projections in connection with delivering its fairness opinion. Please reconcile this response
                                            with your disclosure from page 111 which indicates the following: “With respect to
                                            the financial projections referred to above and any other forecasts or forward looking information,
                                            Scalar assumed, at the direction of the management of Petra, that such projections, forecasts
                                            and information were reasonably prepared and reflected the best then available estimates
                                            and good faith judgments of the matters covered thereby.” With reference to Annex D-1,
                                            also revise to identify the “internal financial statements” reviewed by Scalar
                                            and, irrespective of reliance, revise to clarify whether Scalar received financial projections
                                            prepared by either Petra or Revelation.

RESPONSE: The Company acknowledges the Staff’s
comment and has revised the disclosure throughout the document to clarify that that Scalar did not rely on any financial projections
in connection with delivering its fairness opinion. Annex D has also been revised to identify the internal financial statements reviewed
by Scalar.

11. We
                                            note that Scalar’s opinion indicates that the “Merger Consideration is fair,
                                            from a financial point of view, to Petra as of September 17, 2021.” We also note; however,
                                            that your disclosures on pages 146 and 241, and your Form S-1 IPO prospectus disclosures,
                                            represent that a fairness opinion would address fairness viewed from the standpoint of Petra’s
                                            “unaffiliated stockholders.” In light of these disclosures, please tell us what
                                            consideration the Petra Board has given to the adequacy of Scalar’s September 17 opinion
                                            for purposes of consummating the business combination.

RESPONSE:
The Company acknowledges the Staff’s comment and advises the Staff that Scalar has revised its opinion letter to clarify that the
opinion addresses fairness viewed from the standpoint of Petra’s “unaffiliated stockholders.”

Executive
Officers and Directors of Revelation

Voting
Agreements, page 194

12. We
                                            note your response to prior comment 30. Please revise your description of the AXA Voting
                                            Agreement in this section to clarify, if true, that the agreement will terminate upon the
                                            consummation of the Business Combination, as indicated in your response letter.

RESPONSE: The Company acknowledges the Staff’s
comment and has revised page 198 to add the requested disclosure.

Certain
Relationships and Related Person Transactions, page 239

13. We
                                            note your response to prior comment 31 and re-issue. Please revise this section to disclose
                                            the valuations accorded to Revelation in December 2020, May 2020 and January 2021 when LifeSci
                                            made its investments.

RESPONSE: The Company acknowledges the Staff’s
comment and has revised page 244 to add the requested disclosure..

Please
call me at (212) 407-4063 if you would like additional information with respect to any of the foregoing. Thank you.

    Sincerely,

    /s/
    Alex Weniger-Araujo

    Alex
    Weniger-Araujo

    Partner

United States securities and exchange commission logo
November 26, 2021
Andreas Typaldos
Chief Executive Officer
Petra Acquisition, Inc.
5 West 21st Street
New York, NY 10010
Re:Petra Acquisition Inc.
Amendment No. 1 to Registration Statement on Form S-4
Filed November 4, 2021
File No. 333-259638
Dear Mr. Typaldos:
            We have reviewed your amended 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.  Unless we note
otherwise, our references to prior comments are to comments in our October 25, 2021 letter.
Amendment No. 1 to Registration Statement on Form S-4
Cover Page
1.We note your response to prior comment 1. Please revise your cover page to disclose the
ownership percentages of the Sponsor and Insiders, the Public Stockholders and the
existing holders of Revelation's stock in the combined company.

 FirstName LastNameAndreas Typaldos
 Comapany NamePetra Acquisition, Inc.
 November 26, 2021 Page 2
 FirstName LastName
Andreas Typaldos
Petra Acquisition, Inc.
November 26, 2021
Page 2
Q. Did the Board obtain a third-party valuation or fairness opinion in determining whether or not
to proceed with the Business Combination?, page 8
2.Please revise to address the following:
•Clarify that the Petra Board approved the business combination agreement prior to
receipt of the fairness opinion.
•Quantify the deferred underwriting, Business Combination, and other fees payable to
LifeSci Capital upon merger consummation.
•Disclose LifeSci’s ownership stake in Revelation.

In addition, add a separate Question and Answer immediately following the existing one
to highlight and explain that LifeSci negotiated the terms of the business combination
agreement on behalf of Petra notwithstanding interests different from or in addition
to those held by other Petra stockholders.  With reference to the disclosure on page 107,
the Q&A should explain that LifeSci negotiated with Revelation concerning the amount of
LifeSci’s deferred underwriting fee at the same time that LifeSci and Revelation were
negotiating Revelation’s valuation for purposes of determining how much equity would be
allocated to the parties in the business combination.
Summary of the Proxy Statement/Prospectus
Petra's Reasons for the Business Combination, page 21
3.We note your response to prior comment 10 and re-issue. The risks described beginning
on page 22 are primarily risks related to the business combination process and COVID-19
and are not risks or uncertainties that are specific to Revelation and its business. Based on
your response letter and in particular your statement that the risks related to Revelation
that Petra's board of directors considered are set forth beginning on page 22 of the
document, it appears that Petra's board of directors did not consider risks unique to
Revelation and its business in making its decision to approve the Business Combination.
Accordingly, please revise your disclosure here and on page 110 to clarify, if true, that
Petra's board of directors did not evaluate risks that were specific and unique to
Revelation in making its decision to approve the Business Combination.

Please also revise your disclosure here and on page 110 to disclose the material risks to
unaffiliated investors presented by taking the company public through a merger rather
than an underwritten offering.
4.We note your statements here and pages 109 and 152 indicating that data from REVDx-
501 correlate well with PCR for SARS-CoV-2. Please revise to reflect your disclosure on
page 169 which indicates that REVDx-501 returned numerous positive tests from test
samples that were PCR negative.

 FirstName LastNameAndreas Typaldos
 Comapany NamePetra Acquisition, Inc.
 November 26, 2021 Page 3
 FirstName LastName
Andreas Typaldos
Petra Acquisition, Inc.
November 26, 2021
Page 3
Revelation's Reasons for the Business Combination, page 23
5.We note your response to prior comment 7. Please revise your disclosure in this section to
clarify, if true, that the pro forma enterprise value of approximately $128M considered by
Revelation excluded pro forma cash, including any funds from the trust account.
6.Please revise here and in the Background of the Business Combination section to explain
why Revelation discontinued its pursuit of the initial public offering in favor of a business
combination with a SPAC entity, particularly given your disclosures that Revelation
received preliminary indications of interest from new institutional investors at valuations
ranging from $120 million to $150 million.  Also, revise to clarify what type of initial
public offering was pursued (e.g., firm commitment, best efforts, etc.).
Risk Factors
The Proposed Charter provides..., page 69
7.Please revise this risk factor to reflect your disclosure elsewhere in the proxy
statement/prospectus that your Delaware exclusive forum provision will not apply to suits
brought to enforce a duty or liability arising under the Exchange Act or any other claim
for which the federal courts have exclusive jurisdiction. Please also revise to reflect your
discussion elsewhere in the proxy statement/prospectus that Section 22 of the Securities
Act creates concurrent jurisdiction for state and federal courts over all actions brought to
enforce any duty or liability created by the Securities Act or the rules and regulations
thereunder. Additionally, please revise to address any risks and impact on investors, such
as increased costs to bring a claim and that that these provisions can discourage claims or
limit inventors' ability to bring a claim in a judicial forum that they find favorable.
Unaudited Pro Forma Combined Condensed Financial Inormation
Unaudited Pro Forma Combined Condensed Balance Sheet, page 94
8.Please revise the adjustments in Notes (C) and (D) in the unaudited pro forma combined
balance sheet since the adjustments do not appear to be included in the correct line based
on the explanation in the Notes.
Background of the Business Combination, page 104
9.With reference to the May 17 entry, please identify the Petra board members who were
informed of the potential conflicts of interest.  With reference to your disclosure on page
110 indicating that Petra directors reviewed and considered LifeSci’s interests “during the
negotiations," discuss how the Petra Board, or the informed board members, reviewed
these interests and what measures, if any, they considered to mitigate the potential impacts
that LifeSci’s conflicts could have on future negotiations. In particular, specifically
discuss whether the Board considered discontinuing LifeSci's involvement in the merger
negotiations.

 FirstName LastNameAndreas Typaldos
 Comapany NamePetra Acquisition, Inc.
 November 26, 2021 Page 4
 FirstName LastName
Andreas Typaldos
Petra Acquisition, Inc.
November 26, 2021
Page 4
Opinion of the Petra Financial Advisor, page 110
10.We note your response to prior comment 22 and your statement that Scalar did not rely on
financial projections in connection with delivering its fairness opinion. Please reconcile
this response with your disclosure from page 111 which indicates the following: "With
respect to the financial projections referred to above and any other forecasts or forward
looking information, Scalar assumed, at the direction of the management of Petra, that
such projections, forecasts and information were reasonably prepared and reflected the
best then available estimates and good faith judgments of the matters covered thereby."
With reference to Annex D-1, also revise to identify the "internal financial statements"
reviewed by Scalar and, irrespective of reliance, revise to clarify whether Scalar received
financial projections prepared by either Petra or Revelation.
11.We note that Scalar’s opinion indicates that the “Merger Consideration is fair, from a
financial point of view, to Petra as of September 17, 2021.” We also note; however, that
your disclosures on pages 146 and 241, and your Form S-1 IPO prospectus disclosures,
represent that a fairness opinion would address fairness viewed from the standpoint of
Petra’s “unaffiliated stockholders.”  In light of these disclosures, please tell us what
consideration the Petra Board has given to the adequacy of Scalar’s September 17 opinion
for purposes of consummating the business combination.
Executive Officers and Directors of Revelation
Voting Agreements, page 194
12.We note your response to prior comment 30. Please revise your description of the AXA
Voting Agreement in this section to clarify, if true, that the agreement will terminate upon
the consummation of the Business Combination, as indicated in your response letter.
Certain Relationships and Related Person Transactions, page 239
13.We note your response to prior comment 31 and re-issue. Please revise this section to
disclose the valuations accorded to Revelation in December 2020, May 2020 and January
2021 when LifeSci made its investments.

 FirstName LastNameAndreas Typaldos
 Comapany NamePetra Acquisition, Inc.
 November 26, 2021 Page 5
 FirstName LastName
Andreas Typaldos
Petra Acquisition, Inc.
November 26, 2021
Page 5
            You may contact Jeanne Bennett at 202-551-3606 or Brian Cascio at 202-551-3676 if
you have questions regarding comments on the financial statements and related matters. Please
contact Alan Campbell at 202-551-4224 or Joe McCann at 202-551-6262 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Alex Weniger-Araujo

CORRESP
1
filename1.htm

    345
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 November
4, 2021

Via
EDGAR

Division
of Corporation Finance

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

 Attn: Alan
Campbell

Joe
McCann

 Re: Petra
Acquisition Inc.

Registration
Statement on Form S-4

Filed September 20, 2021

File
No. 333-259638

Dear
Mr. Campbell and Mr. McCann:

On
behalf of Petra Acquisition Inc. (the “Company”), we are hereby responding to the letter dated October 25,
2021 (the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange
Commission, regarding the Company’s Registration Statement on Form S-4, File No. 333-259638 (“Registration Statement”).
In response to the Comment Letter and to update certain information in the Registration Statement, the Company is filing Amendment No.
1 to the Registration Statement (the “Amended Registration Statement”) with the Commission today.

For
ease of reference, the text of the Staff’s comment is included in bold-face type below, followed by the Company’s response.

Registration
Statement on Form S-4

Cover Page

 1. We
note that your cover page disclosure is five pages in length and duplicates much of the information contained in the Notice that immediately
follows it. Please revise to make the cover page more concise. In your revision, please highlight the business combination consideration
and agreed-upon pre-money valuation of Revelation.

RESPONSE:
The Company acknowledges the Staff’s comment and has revised the cover page to make it more concise and include on the cover
page the requested disclosure.

Market
and Industry Data, page 1

 2. We
note your statements that (i) you have not independently verified the market and industry data contained in the proxy statement/prospectus
or the associated underlying assumptions and (ii) your research has not been verified by any independent source. These statements may
imply an inappropriate disclaimer of responsibility with respect to such information. Please either delete these statements or specifically
state that you are liable for such information.

RESPONSE:
The Company acknowledges the Staff’s comment and has provided updated disclosure on page 1 of the Amended Registration Statement
to indicate Petra’s responsibility for the statements in the proxy statement/prospectus.

Questions
and Answers About the Proposals

What equity stake will current stockholders of Petra and Revelation Equityholders hold in New Revelation
after the Closing?, page 7

 3. Please
revise the response to this question to disclose the sponsor and its affiliates’ total potential ownership interest in the combined
company, assuming exercise and conversion of all securities.

RESPONSE:
The Company acknowledges the Staff’s comment and has provided updated disclosure beginning on page 7  of the Amended Registration
Statement disclosing the sponsor and its affiliates’ total potential ownership interest in the combined company, assuming exercise
and conversion of all securities.

What
interests do Petra’s current officers and directors have in the Business Combination?, page 9

 4. Please
revise the response to this question and your other conflict-of-interest disclosure throughout to clarify if the sponsor and its affiliates
can earn a positive rate of return on their investment, even if other SPAC shareholders experience a negative rate of return in the post-business
combination company.

Please
also quantify the fees that would be payable to LifeSci Capital upon the consummation of the Business Combination.

RESPONSE:
The Company acknowledges the Staff’s comment and has provided updated disclosure beginning on pages 10, 25, 79, 88, and 118
of the Amended Registration Statement. We have also added a new Risk Factor addressing the rate of return risk on page
78.

Summary
of the Proxy Statement/Prospectus

Revelation, page 16

 5. We
note your statement here and on pages 145 and 197 that Revelation’s therapeutics and diagnostic platforms may be applied to a wide array
of viral infections, including SARS- CoV-2, variants of SARS-CoV-2, Influenza A, Influenza B, parainfluenza, respiratory syncytial virus,
rhinovirus, and others. Given Revelation’s current stage of development, it is premature to make this claim. Please revise to remove
this sentence.

We
further note your statement here and on pages 145 and 152 that REVx-99 works by boosting the body’s innate immune system, preventing
the user from becoming infected or activating the innate immune system to combat early infections. You may state that REVx-99 is designed
to boost the body’s innate immune system, with the goal of preventing a user from becoming infected or activating the innate immune system,
but please revise this sentence to avoid the implication that REVx-99 has already demonstrated these characteristics.

RESPONSE:
The Company acknowledges the Staff’s comment and has provided updated disclosure beginning on page 151 of the Amended
Registration Statement.

    2

 6. We
note your statement here and on pages 145 and 197 that REVDx-501 is a rapid point- of-care diagnostic that can be used to detect various
respiratory viral infections. Please revise this sentence here and throughout to reflect your disclosure elsewhere in the document that
REVDx-501 has not been approved for marketing by the FDA or any other regulatory agency.

RESPONSE:
The Company acknowledges the Staff’s comment and has provided updated disclosure beginning on page 16, 27, 36, 37 among others
of the Amended Registration Statement.

Consideration
to th e Revelation Equityholders in the Business Combination, page 17

 7. Please
explain to us how your statement that the implied equity value of $128 million of the post-business combination company, assuming that
shares of Petra trade at approximately $10 per share and that there are no redemptions, is consistent with your disclosure elsewhere
in the prospectus indicating that (i) the combined company would have 19,597,689 shares of common stock outstanding, assuming no redemptions
and (ii) the parties agreed a pre-money valuation of Revelation of $105 million and there is approximately $73.5 million in the trust
account.

RESPONSE:
The Company acknowledges the Staff’s comment and advises the Staff that the referenced disclosure no longer appears in the document.

Reasons
for the Business Combination, page 21

 8. Please
revise the first sentence of the “REVTx-99” bullet to remove any implication that REVTx-99 can (i) be used to prevent or treat
infections and (ii) boosts the body’s immune system and prevents users from becoming infected or activates innate immune response given
that this product candidate is still in clinical trials.

Similarly,
please revise the “REVTx-200” and “REVDx-501” bullets to remove any implication that either one is effective and
to clarify that both are still in development.

RESPONSE:
The Company acknowledges the Staff’s comment and has provided updated disclosure beginning on page 21 of the Amended
Registration Statement.

 9. Please
revise to provide the basis for your statements that (i) Revelation’s products are all based on a solid scientific foundation and (ii)
Revelation has multiple near-term value driving milestones.

RESPONSE:
The Company acknowledges the Staff’s comment and has provided updated disclosure beginning on page 22 of the Amended
Registration Statement.

    3

 10. Please
disclose whether Petra’s board of directors considered any risks related to Revelation in evaluating the Business Combination. If Petra’s
board considered such risks, please disclose them. Please also disclose the material risks to unaffiliated investors presented by taking
the company public through a merger rather than an underwritten offering. These risks could include the absence of due diligence conducted
by an underwriter that would be subject to liability for any material misstatements or omissions in a registration statement.

RESPONSE:
The Company acknowledges the Staff’s comment and advises the Staff that the risks related to Revelation that Petra’s board of directors
considered in evaluating the Business Combination are set forth beginning on page 22 of the Amended Registration Statement. We have
also provided updated disclosure beginning on page 109 of the Amended Registration Statement so that Petra’s reasons for approving
the Business Combination and risks considered in evaluating the same, appear consecutively in the same section.

The
Company has also added a risk factor, beginning on page 83 of the Amended Registration Statement, that discloses the risks to unaffiliated
investors presented by taking the company public through a merger rather than an underwritten offering.

Unaudited
Pro Forma Combined Condensed Consolidated Financial Information Basis of Presentation and Background, page 90

 11. We
note your statement that the Company’s net tangible asset value would not fall below $5,000,001 even in a full redemption scenario. Please
revise to provide the basis for this statement.

RESPONSE:
The Company acknowledges the Staff’s comment and has revised the disclosure to clarify that the business combination will not be consummated if the net tangible asset value would fall below $5,000,001.

Unaudited
Pro Forma Combined Condensed Consolidated Financial Information

Unaudited Pro Forma Condensed Combined Balance Sheet, page 92

 12. Please
explain to us where the adjustment in Note (D) is included in the pro forma condensed combined balance sheet.

RESPONSE:
The Company acknowledges the Staff’s comment and advises the Staff that there was a scriveners error and that there is no Note (D).

 13. Please
expand your description in Note (G) to the pro forma condensed combined balance sheet to explain the circumstances that resulted in the
change of classification of the private warrants from liability to equity upon closing of the business combination.

RESPONSE:
The Company acknowledges the Staff’s comment and has provided updated disclosure beginning on page 94 of the Amended
Registration Statement.

Proposal
1 -- The Business Combination

Proposal Payment of Expenses, page 100

 14. Please
revise this section to disclose the nature of Petra and Merger Sub’s outstanding expenses and the anticipated recipients of these payments.

RESPONSE:
The Company acknowledges the Staff’s comment and has provided updated disclosure beginning on page 101 of the Amended
Registration Statement.

    4

Background
of the Business Combination, page 103

 15. Please
revise this section to describe how Petra’s board of directors determined an initial $75M pre-money valuation of Revelation as well as
how and why Petra agreed to increase the pre-money valuation of Revelation to $105M. In your revisions, please present the calculations
and analysis utilized by Petra’s management and board of directors in determining these valuations. Discuss any forecasts and all material
assumptions underlying the valuations and consideration proposed by either party.

RESPONSE:
The Company acknowledges the Staff’s comment and has provided updated disclosure beginning on page 105 of the Amended
Registration Statement.

 16. Please
revise this section to discuss how Petra’s management and board of directors conducted business and scientific due diligence on Revelation.
To the extent that Petra did not retain third-party experts to conduct scientific due diligence, please revise to explain why Petra’s
board of directors determined that retaining such experts was not necessary.

RESPONSE:
The Company acknowledges the Staff’s comment and has provided updated disclosure beginning on page 107 of the Amended Registration
Statement.

 17. Please
revise your disclosure here and in the Summary of the Proxy Statement/Prospectus, to clarify and highlight, if true, that Petra, Revelation
and their respective representatives, including LifeSci Capital, engaged in transaction discussions and negotiations from May 2021 to
August 20, 2021 before Petra’s board of directors was informed of that LifeSci Venture had conflicts of interest stemming from their
ownership stake in Revelation. Also, revise the Q&A on page 7 to explain why the Board obtained the fairness opinion.

RESPONSE:
The Company acknowledges the Staff’s comment and has provided clarifying disclosure on page 105 and 107 of the Amended Registration
Statement to indicate that the board was aware of the potential conflict throughout the negotiations. The Q&A on page 8 has also been revised.

 18. Please
revise this section to disclose (i) the mechanics of Revelation’s proposed scaling forfeitures of sponsor equity and certain fees and
expenses if Petra’s trust account experienced certain levels of redemptions and (ii) why Petra’s board of directors determined that it
was fair to and in the best interests of Petra and its stockholders to increase the pre-money valuation of Revelation from $75M to $105M
instead of accepting Revelation’s proposed changes regarding sponsor equity and the related fees and expenses.

RESPONSE:
The Company acknowledges the Staff’s comment and has provided updated disclosure beginning on page 107 of the Amended Registration
Statement.

 19. With
reference to the disclosure on page 105, please revise to identify the other transactions that Petra was exploring and disclose why such
transactions were not pursued. Also, please tell us, and revise to indicate if applicable, whether Revelation had discussions with other
SPACs and whether any offers (preliminary or otherwise) were made by or to Revelation.

RESPONSE:
The Company acknowledges the Staff’s comment and has provided revised disclosure beginning on page 106 of the Amended Registration
Statement to clarify that the “other transactions” refers to Target 4 and Target 5 which are discussed on page 105, including
the reasons that discussions with those targets were eventually discontinued.

In
addition, Revelation has informed the Company that Revelation had no discussions with other SPACs and no offers (preliminary or otherwise)
were made by or to Revelation.

    5

 20. Please
revise the disclosure on page 104 concerning the May 19 to May 25 discussions to describe the illustrative pro forma capitalization scenarios
and to explain the aspects of the “structure of the Petra SPAC” that were discussed.

RESPONSE:
The Company acknowledges the Staff’s comment and has provided updated disclosure beginning on page 106  of the Amended Registration
Statement.

The
Petra Board’s Reasons for the Approval of the Business Combination, page 106

 21. Please
provide the reasons why Petra’s Board approved the Business Combination. Please also discuss any risks related to the Business Combination
that were considered by Petra’s Board.

RESPONSE:
The Company acknowledges the Staff’s comment and advises the Staff that the risks related to Revelation that Petra’s board of directors
considered in evaluating the Business Combination are set forth beginning on page 22 of the Amended Registration Statement. We have
also provided updated disclosure beginning on page 109 of the Amended Registration Statement so that Petra’s reasons for approving
the Business Combination and risks considered in evaluating the same, appear consecutively in the same section.

Opinion
of the Petra Financial Advisor, page 107

 22. To
the extent that Scalar relied on financial projections in connection with delivering its fairness opinion, please present these projections
in the filing.

RESPONSE:
The Company acknowledges the Staff’s comment and confirms that Scalar did not rely on financial projections in connection with
delivering its fairness opinion.

 23. We
note the disclosure on page 107 that Scalar compared Revelation to similarly situated public companies. We also note that Revelation’s
lead product candidate has completed a Phase 1 trial but does n

United States securities and exchange commission logo
October 25, 2021
Andreas Typaldos
Chief Executive Officer
Petra Acquisition, Inc.
5 West 21st Street
New York, NY 10010
Re:Petra Acquisition Inc.
Registration Statement on Form S-4
Filed September 20, 2021
File No. 333-259638
Dear Mr. Typaldos:
            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-4
Cover Page
1.We note that your cover page disclosure is five pages in length and duplicates much of the
information contained in the Notice that immediately follows it.  Please revise to make the
cover page more concise.  In your revision, please highlight the business combination
consideration and agreed-upon pre-money valuation of Revelation.
Market and Industry Data, page 1
2.We note your statements that (i) you have not independently verified the market and
industry data contained in the proxy statement/prospectus or the associated underlying
assumptions and (ii) your research has not been verified by any independent source. These
statements may imply an inappropriate disclaimer of responsibility with respect to such

 FirstName LastNameAndreas Typaldos
 Comapany NamePetra Acquisition, Inc.
 October 25, 2021 Page 2
 FirstName LastNameAndreas Typaldos
Petra Acquisition, Inc.
October 25, 2021
Page 2
information. Please either delete these statements or specifically state that you are liable
for such information.
Questions and Answers About the Proposals
What equity stake will current stockholders of Petra and Revelation Equityholders hold in New
Revelation after the Closing?, page 7
3.Please revise the response to this question to disclose the sponsor and its affiliates’ total
potential ownership interest in the combined company, assuming exercise and conversion
of all securities.
What interests do Petra's current officers and directors have in the Business Combination?, page
9
4.Please revise the response to this question and your other conflict-of-interest disclosure
throughout to clarify if the sponsor and its affiliates can earn a positive rate of return on
their investment, even if other SPAC shareholders experience a negative rate of return in
the post-business combination company.

Please also quantify the fees that would be payable to LifeSci Capital upon the
consummation of the Business Combination.
Summary of the Proxy Statement/Prospectus
Revelation, page 16
5.We note your statement here and on pages 145 and 197 that Revelation's therapeutics and
diagnostic platforms may be applied to a wide array of viral infections, including SARS-
CoV-2, variants of SARS-CoV-2, Influenza A, Influenza B, parainfluenza, respiratory
syncytial virus, rhinovirus, and others. Given Revelation's current stage of development, it
is premature to make this claim. Please revise to remove this sentence.

We further note your statement here and on pages 145 and 152 that REVx-99 works by
boosting the body's innate immune system, preventing the user from becoming infected or
activating the innate immune system to combat early infections. You may state that
REVx-99 is designed to boost the body's innate immune system, with the goal of
preventing a user from becoming infected or activating the innate immune system, but
please revise this sentence to avoid the implication that REVx-99 has already
demonstrated these characteristics.
6.We note your statement here and on pages 145 and 197 that REVDx-501 is a rapid point-
of-care diagnostic that can be used to detect various respiratory viral infections. Please
revise this sentence here and throughout to reflect your disclosure elsewhere in the
document that REVDx-501 has not been approved for marketing by the FDA or any other
regulatory agency.

 FirstName LastNameAndreas Typaldos
 Comapany NamePetra Acquisition, Inc.
 October 25, 2021 Page 3
 FirstName LastNameAndreas Typaldos
Petra Acquisition, Inc.
October 25, 2021
Page 3
Consideration to the Revelation Equityholders in the Business Combination, page 17
7.Please explain to us how your statement that the implied equity value of $128 million of
the post-business combination company, assuming that shares of Petra trade at
approximately $10 per share and that there are no redemptions, is consistent with your
disclosure elsewhere in the prospectus indicating that (i) the combined company would
have 19,597,689 shares of common stock outstanding, assuming no redemptions and (ii)
the parties agreed a pre-money valuation of Revelation of $105 million and there is
approximately $73.5 million in the trust account.
Reasons for the Business Combination, page 21
8.Please revise the first sentence of the "REVTx-99" bullet to remove any implication that
REVTx-99 can (i) be used to prevent or treat infections and (ii) boosts the body's immune
system and prevents users from becoming infected or activates innate immune
response given that this product candidate is still in clinical trials.

Similarly, please revise the "REVTx-200" and "REVDx-501" bullets to remove any
implication that either one is effective and to clarify that both are still in development.
9.Please revise to provide the basis for your statements that (i) Revelation's products are all
based on a solid scientific foundation and (ii) Revelation has multiple near-term value
driving milestones.
10.Please disclose whether Petra's board of directors considered any risks related to
Revelation in evaluating the Business Combination. If Petra's board considered such risks,
please disclose them.  Please also disclose the material risks to unaffiliated investors
presented by taking the company public through a merger rather than an underwritten
offering. These risks could include the absence of due diligence conducted by an
underwriter that would be subject to liability for any material misstatements or omissions
in a registration statement.
Unaudited Pro Forma Combined Condensed Consolidated Financial Information
Basis of Presentation and Background, page 90
11.We note your statement that the Company's net tangible asset value would not fall below
$5,000,001 even in a full redemption scenario. Please revise to provide the basis for this
statement.
Unaudited Pro Forma Combined Condensed Consolidated Financial Information
Unaudited Pro Forma Condensed Combined Balance Sheet, page 92
12.Please explain to us where the adjustment in Note (D) is included in the pro forma
condensed combined balance sheet.

13.Please expand your description in Note (G) to the pro forma condensed combined balance

 FirstName LastNameAndreas Typaldos
 Comapany NamePetra Acquisition, Inc.
 October 25, 2021 Page 4
 FirstName LastNameAndreas Typaldos
Petra Acquisition, Inc.
October 25, 2021
Page 4
sheet to explain the circumstances that resulted in the change of classification of the
private warrants from liability to equity upon closing of the business combination.

Proposal 1 -- The Business Combination Proposal
Payment of Expenses, page 100
14.Please revise this section to disclose the nature of Petra and Merger Sub's outstanding
expenses and the anticipated recipients of these payments.
Background of the Business Combination, page 103
15.Please revise this section to describe how Petra's board of directors determined an initial
$75M pre-money valuation of Revelation as well as how and why Petra agreed to increase
the pre-money valuation of Revelation to $105M. In your revisions, please present the
calculations and analysis utilized by Petra's management and board of directors in
determining these valuations.  Discuss any forecasts and all material assumptions
underlying the valuations and consideration proposed by either party.
16.Please revise this section to discuss how Petra's management and board of directors
conducted business and scientific due diligence on Revelation. To the extent that Petra did
not retain third-party experts to conduct scientific due diligence, please revise to explain
why Petra's board of directors determined that retaining such experts was not necessary.
17.Please revise your disclosure here and in the Summary of the Proxy Statement/Prospectus,
to clarify and highlight, if true, that Petra, Revelation and their respective representatives,
including LifeSci Capital, engaged in transaction discussions and negotiations from May
2021 to August 20, 2021 before Petra's board of directors was informed of that LifeSci
Venture had conflicts of interest stemming from their ownership stake in Revelation.
Also, revise the Q&A on page 7 to explain why the Board obtained the fairness opinion.
18.Please revise this section to disclose (i) the mechanics of Revelation's proposed scaling
forfeitures of sponsor equity and certain fees and expenses if Petra's trust account
experienced certain levels of redemptions and (ii) why Petra's board of directors
determined that it was fair to and in the best interests of Petra and its stockholders to
increase the pre-money valuation of Revelation from $75M to $105M instead of accepting
Revelation's proposed changes regarding sponsor equity and the related fees and expenses.
19.With reference to the disclosure on page 105, please revise to identify the other
transactions that Petra was exploring and disclose why such transactions were not
pursued.  Also, please tell us, and revise to indicate if applicable, whether Revelation had
discussions with other SPACs and whether any offers (preliminary or otherwise) were
made by or to Revelation.
20.Please revise the disclosure on page 104 concerning the May 19 to May 25 discussions to
describe the illustrative pro forma capitalization scenarios and to explain the aspects of
the "structure of the Petra SPAC" that were discussed.

 FirstName LastNameAndreas Typaldos
 Comapany NamePetra Acquisition, Inc.
 October 25, 2021 Page 5
 FirstName LastNameAndreas Typaldos
Petra Acquisition, Inc.
October 25, 2021
Page 5
The Petra Board's Reasons for the Approval of the Business Combination, page 106
21.Please provide the reasons why Petra's Board approved the Business Combination. Please
also discuss any risks related to the Business Combination that were considered by Petra's
Board.
Opinion of the Petra Financial Advisor, page 107
22.To the extent that Scalar relied on financial projections in connection with delivering its
fairness opinion, please present these projections in the filing.
23.We note the disclosure on page 107 that Scalar compared Revelation to similarly situated
public companies.  We also note that Revelation's lead product candidate has completed a
Phase 1 trial but does not appear to have clinical efficacy data at this point.  Accordingly,
please revise to clarify whether Scalar selected companies that had clinical efficacy data
or had received regulatory approval for its lead product candidate.  If so, please revise the
tables to show the development stage attained by each identified company.
Revelation Selected Comparable SPAC Reverse Merger Transactions Analysis, page 110
24.We note your statement that Scalar selected the transactions in the table based on industry
sector and "other transaction characteristics." Please revise to specify the other transaction
characteristics that Scalar used in determining that these companies were similar to
Revelation.
Overview, page 145
25.Please revise to disclose when Revelation commenced the Phase 1 clinical trial
of REVTx-99 in Australia.  With a view to disclosure, please tell us whether development
efforts relating to REVTx-99 were undertaken prior to Revelation's formation in May
2020.
Information About Revelation
Our Pipeline, page 147
26.Your disclosure throughout the prospectus indicates that REVTx-99 has not yet
commenced a Phase 2 clinical trial. Accordingly, please shorten the arrows for REVTx-99
in the pipeline chart so that they do not extend past the Phase 1 column.

Your pipeline chart also indicates that Revelation has completed clinical testing for
REVDx-501. Please expand your disclosure in the Business sections to fully describe the
clinical trials of REVDx-501.
Intellectual Property, page 167
27.Please revise this section to disclose the jurisdictions of your patent applications as well as
the expiration dates of the patents, if issued.

 FirstName LastNameAndreas Typaldos
 Comapany NamePetra Acquisition, Inc.
 October 25, 2021 Page 6
 FirstName LastNameAndreas Typaldos
Petra Acquisition, Inc.
October 25, 2021
Page 6
Description of New Revelation's Securities After the Business Combination
Exclusive Forum, page 218
28.Please revise here and elsewhere in your registration statement to disclose whether New
Revelation's forum selection provision applies to actions arising under the Securities Act.
In that regard, 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. If the provision applies to
Securities Act claims, please also revise to state that there is uncertainty as to whether a
court would enforce such provision and that investors cannot waive compliance with the
federal securities laws and the rules and regulations thereunder.
Beneficial Ownership of Securities, page 230
29.Please revise the footnotes to the beneficial ownership table to disclose the natural persons
who hold voting and/or dispositive control over the shares held by Polar Multi-Strategy
Master Fund and AXA IM Prime Impact Fund.
Certain Relationships and Related Person Transactions, page 233
30.Please revise this section to disclose the material terms of the AXA Voting Agreement
discussed on page 188 and file the agreement as an exhibit to your registration statement.
31.Please revise to disclose the valuations accorded to Revelation in December 2020, May
2020 and January 2021 when LifeSci made its investments.
Material U.S. Federal Income Tax Consequences
U.S. Holders, page 238
32.Please revise this section to indicate that it constitutes the opinion of your tax counsel and
file the opinion as an exhibit to your registration statement.  We also note your disclosure
that the parties intend for the merger to be treated for U.S. federal income tax purposes as
a “reorganization” within the meaning of Section368(a) of the Internal Revenue Code
and/or as part of a tax-deferred transaction pursuant to Section 351 of the Code.  Please
revise your disclosure to express a firm opinion for each material tax consequence, or
explain why such an opinion cannot be given, and remove language stating that it is
intended that, or generally, certain material tax consequences will apply. Please also
remove any statement that assumes the material tax consequences at issue. Refer to
Section III of Staff Legal Bulletin 19.

Exhibits
33.Please file the Global Health Agreement discussed on page 166 as an exhibit to your
registration statement.

 FirstName LastNameAndreas Typaldos
 Comapany NamePetra Acquisition, Inc.
 October 25, 2021 Page 7
 FirstName LastName
Andreas Typaldos
Petra Acquisition, Inc.
October 25, 2021
Page 7
            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 r