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<DOCUMENT>
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<TEXT>
 April 27, 2026

Manmeet Soni
Chief Operating Officer and Chief Financial Officer
Summit Therapeutics Inc.
601 Brickell Key Drive, Suite 1000
Miami, FL 33131

 Re: Summit Therapeutics Inc.
 Form 10-K for the fiscal year ended December 31, 2025
 Filed February 23, 2026
 File No. 001-36866
Dear Manmeet Soni:

 We have completed our review of your filing. We remind you that the
company and its
management are responsible for the accuracy and adequacy of their disclosures,
notwithstanding
any review, comments, action or absence of action by the staff.

 Sincerely,

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

CORRESP
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 CORRESP

 April 16, 2026 Via
EDGAR United States Securities and Exchange Commission
 Division of Corporation Finance Office of Life Sciences
 100 F Street, N.E. Washington, D.C. 20549
 Re: Summit Therapeutics Inc.
 Form 10-K for Fiscal Year Ended December 31, 2025
 File No. 001-36866
 Ladies and Gentlemen: Set forth below are the responses of
Summit Therapeutics Inc. (the “ Company , ” “ we ,” “ us ” or “ our ”), to the comments received from the staff of the Division of Corporation
Finance (the “ Staff ”) of the U.S. Securities and Exchange Commission (the “ Commission ”) by letter dated April 2, 2026. For your convenience, we have recited the Staff’s comment in
boldface type and provided our response to such comment immediately thereafter. Form 10-K For Fiscal Year
Ended December 31, 2025 Product Pipeline, Page 4

 1.
 Regarding the disclosure on page 6 about collaborating with multiple institutions globally and your
investigator-sponsored trials program across several disease areas, please tell us and revise your future filings, beginning with your March 31, 2026 Form 10-Q, to specifically address the collaborations
entered into with GSK and Revolution Medicines and provide the significant related terms of each, including any consideration exchanged thus far. We note these collaborations were entered into prior to the filing of your Form 10-K and are highlighted in your fourth quarter of 2025 earnings release, earnings call and accompanying slides/presentation.
 RESPONSE: In response to the Staff’s request, the
Company respectfully acknowledges the Staff’s comment and advises the Staff that there has not been any cash consideration exchanged in connection with our collaborations with GSK and Revolution Medicines to date. These are agreements to
engage in one or more clinical trials combining ivonescimab with a third-party drug, where Summit is providing ivonescimab for the trial. The third party is acting as the study sponsor and is responsible for the associated costs of the studies
beyond the cost of ivonescimab. For these reasons, these collaborations do not include any upfront payments, milestone payments, or royalty sharing provisions.
 In future filings, beginning with our Form 10-Q for the quarter ended March 31, 2026, the Company will provide
additional disclosure related to the collaborations with GSK and Revolution Medicines and the significant related terms of each collaboration, including whether any cash consideration has been exchanged. The following disclosure will be included in
our Form 10-Q for the quarter ended March 31, 2026:

 In June 2025, the Company entered into a clinical trial collaboration with Revolution Medicines, Inc.
(“RevMed”) to evaluate ivonescimab in combination with three RevMed RAS(ON) inhibitors (the “RevMed Collaboration”). In January 2026, the Company entered into a clinical trial collaboration with GSK plc to evaluate
ivonescimab in combination with GSK’s novel B7-H3, risvutatug rezetecan, in multiple solid tumors (the “GSK Collaboration”). Neither the RevMed Collaboration nor the GSK Collaboration include
upfront payments, milestone payments, or royalty sharing provisions. For the quarter ended March 31, 2026, there was no cash consideration exchanged in connection with either the RevMed Collaboration or the GSK Collaboration.
 Form 10-K For Fiscal Year Ended December 31, 2025
 Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 70
 Results of Operations, Page 73

 2.
 Your research and development (R&D) expenses increased more than 220% during 2025 and also made up half
of your $1.08 billion net loss for the year ended December 31, 2025 and 75% of your $221.3 million net loss for the year ended December 31, 2024. For 2025, oncology clinical trial related costs made up half of your R&D
expenses, yet the explanation provided for the 164% increase in these costs during the year appears limited, i.e., you attribute the large change primarily to new clinical trials added and current clinical trials expanded. Given: i) the significance
of oncology clinical trial related costs to consolidated R&D and, in turn, the significance of consolidated R&D to your results of operations; ii) the multiple clinical trials which you are currently conducting; and iii) the
multiple indications for which you are currently evaluating ivonescimab, please tell us whether your oncology clinical trial related costs can be further disaggregated by indication, trial or some other level and revise future
filings as applicable. RESPONSE:
 In response to the Staff’s request, the Company proposes to further disaggregate its R&D disclosure to track R&D expenses by certain expense
categories. All of our R&D expenses are attributable to our ivonescimab program; the majority of these expenses are shared among various clinical trials, and as such, we do not track expenses by indication. The following table summarizes
major categories of our R&D expenses incurred during the periods indicated:

 Three Months Ended March 31,

 (in millions)

 2026

 2025

 $ Change

 Third-party research and development expenses:

 Clinical trials related expenses

 $
 [   ]

 $
 [   ]

 $
 [   ]

 Expenses related to manufacturing and purchasing of clinical trials related materials

 [   ]

 [   ]

 [   ]

 Other external costs

 [   ]

 [   ]

 [   ]

 Internal expenses:

 Personnel-related expenses (excluding stock-based compensation)

 [   ]

 [   ]

 [   ]

 Stock-based compensation

 [   ]

 [   ]

 [   ]

 Total research and development expenses

 $
 [   ]

 $
 [   ]

 $
 [   ]

 Please direct any questions that you have with respect to the foregoing, or any requests for additional
supplemental information required by the Staff, to the undersigned at Manmeet.Soni@smmttx.com, or to Katherine Terrell Frank at kfrank@velaw.com.

 Sincerely,

 Summit Therapeutics Inc.

 By:

 /s/ Manmeet Soni

 Name: Manmeet Soni

 Title: Chief Operating Officer and Chief Financial Officer
 cc: Robert Duggan,
Chairman and Co-Chief Executive Officer Katherine Terrell Frank, Vinson & Elkins L.L.P.

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<TEXT>
 April 2, 2026

Manmeet Soni
Chief Operating Officer and Chief Financial Officer
Summit Therapeutics Inc.
601 Brickell Key Drive, Suite 1000
Miami, FL 33131

 Re: Summit Therapeutics Inc.
 Form 10-K for the fiscal year ended December 31, 2025
 Filed February 23, 2026
 File No. 001-36866
Dear Manmeet Soni:

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

 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, 2025
Product Pipeline, page 4

1. Regarding the disclosure on page 6 about collaborating with multiple
institutions
 globally and your investigator-sponsored trials program across several
disease areas,
 please tell us and revise your future filings, beginning with your March
31, 2026 Form
 10-Q, to specifically address the collaborations entered into with GSK
and Revolution
 Medicines and provide the significant related terms of each, including
any consideration
 exchanged thus far. We note these collaborations were entered into prior
to the filing of
 your Form 10-K and are highlighted in your fourth quarter of 2025
earnings release,
 earnings call and accompanying slides/presentation.
Management s Discussion and Analysis of Financial Condition and Results of
Operations, page
70
Results of Operations, page 73

2. Your research and development (R&D) expenses increased more then 220%
during 2025
 and also made up half of your $1.08 billion net loss for the year ended
December 31,
 April 2, 2026
Page 2

 2025 and 75% of your $221.3 million net loss for the year ended December
31, 2024.
 For 2025, oncology clinical trial related costs made up half of your R&D
expenses, yet
 the explanation provided for the 164% increase in these costs during the
year appears
 limited, i.e., you attribute the large change primarily to new clinical
trials added and
 current clinical trials expanded. Given: i) the significance of oncology
clinical trial
 related costs to consolidated R&D and, in turn, the significance of
consolidated R&D to
 your results of operations; ii) the multiple clinical trials which you
are currently
 conducting; and iii) the multiple indications for which you are
currently evaluating
 ivonescimab, please tell us whether your oncology clinical trial related
costs can be
 further disaggregated by indication, trial or some other level and
revise future filings as
 applicable.
 In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

 Please contact Jenn Do at 202-551-3743 or Daniel Gordon at 202-551-3486
with any
questions.

 Sincerely,

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

January 21, 2025
Robert Duggan
Chairman and Co-Chief Executive Officer
Summit Therapeutics, Inc.
601 Brickell Key Drive, Suite 1000
Miami, FL 33131
Re:Summit Therapeutics, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-36866
Dear Robert Duggan:
            We have completed our review of your filing. 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

CORRESP
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Document

January 6, 2025

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

Re: Summit Therapeutics Inc.

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

File No. 001-36866

Ladies and Gentlemen:

Set forth below are the responses of Summit Therapeutics Inc. (the “Company,” “we,” “us” or “our”), to the comments received from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) by letter dated December 19, 2024. For your convenience, we have recited the Staff’s comment in boldface type and provided our response to such comment immediately thereafter.

Form 10-K For Fiscal Year Ended December 31, 2023

Form 8-K Filed February 20, 2024

Exhibit 99.1, page 1

1.Certain of your non-GAAP measures include an adjustment for payments made to acquire in-process research and development (IPR&D) from Akeso, beginning in 2023. We note the company’s focus on the discovery, development, and commercialization of medicinal therapies. In this regard, it appears the cost for licenses that will be utilized to further the company’s focus and mission would be normal in the course of the company’s operations. Please tell us how you determined that the adjustments to exclude IPR&D are consistent with Question 100.01 of the CD&I on Non-GAAP Financial Measures.

RESPONSE:

The Company acknowledges the Staff’s comment and advises the Staff that in its future filings that include non-GAAP financial measures, for all periods presented, the Company will no longer adjust for in-process research and development expenses. The Company will recast prior period information to conform to this revised presentation and will provide a footnote to the non-GAAP reconciliation tables addressing the change as compared to previously furnished information.

*****

Please direct any questions that you have with respect to the foregoing, or any requests for additional supplemental information required by the Staff, to the undersigned at Manmeet.Soni@smmttx.com, or to Katherine Terrell Frank at kfrank@velaw.com.

Sincerely,

Summit Therapeutics Inc.

By: /s/ Manmeet Soni

Name: Manmeet Soni

Title Chief Operating Officer and Chief Financial Officer

cc:

Robert Duggan, Chairman and Co-Chief Executive Officer

Katherine Terrell Frank, Vinson & Elkins L.L.P.

December 19, 2024
Robert Duggan
Chairman and Co-Chief Executive Officer
Summit Therapeutics, Inc.
601 Brickell Key Drive, Suite 1000
Miami, FL 33131
Re:Summit Therapeutics, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-36866
Dear Robert Duggan:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2023
Form 8-K Filed February 20, 2024
Exhibit 99.1, page 1
1.
Certain of your non-GAAP measures include an adjustment for payments made to
acquire in-process research and development (IPR&D) from Akeso, beginning in
2023. We note the company’s focus on the discovery, development, and
commercialization of medicinal therapies. In this regard, it appears that costs for
licenses that will be utilized to further the company’s focus and mission would be
normal in the course of the company’s operations. Please tell us how you determined
that the adjustments to exclude IPR&D are consistent with Question 100.01 of the
C&DI on Non-GAAP Financial Measures.
            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.

December 19, 2024
Page 2
            Please contact Tracie Mariner at 202-551-3744 or Kevin Vaughn at 202-551-3494
with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences

CORRESP
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SUMMIT THERAPEUTICS INC.

601 Brickell Key Drive, Suite
1000

Miami, FL 33131

(650) 460-8308

February
23, 2024

Via
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    Summit
    Therapeutics Inc.

    Registration
Statement on Form S-3

    File No. 333-277169

    Request for Acceleration

Ladies
and Gentlemen:

Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, Summit Therapeutics Inc. (the “Registrant”)
hereby requests acceleration of the effective date of its Registration Statement on Form S-3 (File No. 333-277169) (the “Registration
Statement”), so that it may become effective at 4:00 p.m. Eastern time on February 27, 2024 or as soon thereafter as practicable.

The
Registrant hereby acknowledges that:

    (a)
    should
    the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority,
    declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration
    Statement;

    (b)
    the
    action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective,
    does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration
    Statement; and

    (c)
    the
        Registrant may not assert staff comments and the declaration of effectiveness of the Registration Statement as a defense in any
        proceeding initiated by the Commission or any person under the federal securities laws of the United States.

    We
    request that we be notified of such effectiveness by a telephone call to Adam Finerman, of Baker & Hostetler LLP, at (212) 589-4233
    or afinerman@bakerlaw.com.

    [Remainder
    of this page is intentionally left blank]

    Very truly yours,

    SUMMIT THERAPEUTICS INC.

    By:
    /s/
                                       Ankur Dhingra

    Name:
    Ankur
    Dhingra

    Title:
    Chief Financial Officer

United States securities and exchange commission logo
February 22, 2024
Robert W. Duggan
Chairman and Chief Executive Officer
Summit Therapeutics Inc.
601 Brickell Key Drive, Suite 1000
Miami, FL 33131
Re:Summit Therapeutics Inc.
Registration Statement on Form S-3
Filed February 20, 2024
File No. 333-277169
Dear Robert W. Duggan:
            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:       Adam Finerman, Esq.

CORRESP
1
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SUMMIT
THERAPEUTICS INC.

2882
Sand Hill Road, Suite 106

Menlo
Park, CA 94025

(650)
460-8308

April
25, 2023

Via
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    Summit
    Therapeutics Inc.

    Registration
    Statement on Form S-3

    File
    No. 333-270656

    Request
    for Acceleration

Ladies
and Gentlemen:

Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, Summit Therapeutics Inc. (the “Registrant”)
hereby requests acceleration of the effective date of its Registration Statement on Form S-3 (File No. 333-270656) (the “Registration
Statement”), so that it may become effective at 4:00 p.m. Eastern time on April 27, 2023 or as soon thereafter as practicable.

The
Registrant hereby acknowledges that:

    (a)
    should
    the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority,
    declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration
    Statement;

    (b)
    the
    action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective,
    does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration
    Statement; and

    (c)
    the
    Registrant may not assert staff comments and the declaration of effectiveness of the Registration Statement as a defense in any proceeding
    initiated by the Commission or any person under the federal securities laws of the United States.

    We
    request that we be notified of such effectiveness by a telephone call to Adam Finerman, of Baker & Hostetler LLP, at (212) 589-4233
    or afinerman@bakerlaw.com.

    [Remainder of this page is intentionally left blank]

    Very truly yours,

    SUMMIT THERAPEUTICS INC.

    By:

    /s/ Ankur Dhingra

    Name:

    Ankur Dhingra

    Title:

    Chief Financial Officer

United States securities and exchange commission logo
March 22, 2023
Ankur Dhingra
Chief Financial Officer
Summit Therapeutics Inc.
2882 Sand Hill Road, Suite 106
Menlo Park, CA 94025
Re:Summit Therapeutics Inc.
Registration Statement on Form S-3
Filed March 17, 2023
File No. 333-270656
Dear Ankur Dhingra:
            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 Doris Stacey Gama at 202-551-3188 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Adam Finerman, Esq.

CORRESP
1
filename1.htm

SUMMIT
THERAPEUTICS INC.

2882
Sand Hill Road, Suite 106

Menlo
Park, CA 94025

(44)-0-1235-443-939

January
31, 2023

Via
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    Summit
    Therapeutics Inc.

    Registration Statement on Form S-3

    File
No. 333-268932

    Request
for Acceleration

Ladies
and Gentlemen:

Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, Summit Therapeutics Inc. (the “Registrant”)
hereby requests acceleration of the effective date of its Registration Statement on Form S-3 (File No. 333-268932) (the “Registration
Statement”), so that it may become effective at 4:00 p.m. Eastern time on February 3, 2023 or as soon thereafter as practicable.

The
Registrant hereby acknowledges that:

    (a)
    should
    the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority,
    declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration
    Statement;

    (b)
    the
    action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective,
    does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration
    Statement; and

    (c)
    the
    Registrant may not assert staff comments and the declaration of effectiveness of the Registration Statement as a defense in any proceeding
    initiated by the Commission or any person under the federal securities laws of the United States.

    We
request that we be notified of such effectiveness by a telephone call to Adam Finerman, of Baker & Hostetler LLP, at (212) 589-4233
or afinerman@bakerlaw.com.

[Remainder
of this page is intentionally left blank]

    Very
    truly yours,

    SUMMIT
    THERAPEUTICS INC.

    By:

    /s/
    Ankur Dhingra

    Name:

    Ankur
    Dhingra

    Title:

    Chief
    Financial Officer

[Signature Page to Request
for Acceleration]

CORRESP
1
filename1.htm

  Baker&Hostetler
                         LLP

                         45 Rockefeller Plaza

                         New York, NY 1011

  January
20, 2023
  T 212.589.4200

      F 212.589.4201

      www.bakerlaw.com

  Adam W. Finerman

direct dial: 212.589.4233

afinerman@bakerlaw.com

Via
EDGAR

    Division
    of Corporation Finance

    United States Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549

Re:

 Summit
                                            Therapeutics Inc.

                                                                                                                                                                                                      Registration
                                            Statement on Form S-3

                                                                                Filed
                                            December 21, 2022

                                                                                File
                                            No. 333-268932

Dear
Sir/Madam:

On
behalf of Summit Therapeutics Inc., a Delaware corporation (the “Company”), set forth below are responses (this “Response
Letter”) to the comments of the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities
and Exchange Commission (the “Commission”) contained in the letter dated January 12, 2023 (the “Comment Letter”)
relating to the Company’s Registration Statement on Form S-3, File No. 333-268932, filed with the Commission on December 21, 2022
(the “Registration Statement”). The Company has filed herewith Amendment No. 1 (the “Amendment”)
to the Registration Statement.

The
headings and numbered paragraphs of this Response Letter correspond to the headings and paragraph numbers contained in the Comment Letter,
and, to facilitate the Staff’s review, we have reproduced the text of the Staff’s comments in italicized print. Capitalized
terms used herein and otherwise not defined herein shall have the meanings assigned to such terms in the Registration Statement.

Division
of Corporation Finance

January
20, 2023

Page
2

Registration
Statement on Form S-3

Subscription
Price, page 40

    1.
    Please
    revise to explain why the Board formed a Special Committee and identify the members of that committee.

RESPONSE:
In response to the Staff’s comment, the Company has revised its disclosure on page 41 of the Registration Statement.

    2.
    We
    note your disclosure that in determining the Subscription Price the Special Committee considered the average price for the 30-day
    period prior to the filing of the preliminary proxy statement on November 29, 2022.  With a view to disclosure and with reference
    to your risk factor disclosure at the top of page 31, please tell what consideration, if any, the Special Committee or Board
    has given or will give to revising the Initial Price to reflect more recent market trading.  In this regard, we note that the
    stock price increased significantly beginning in early December. To the extent that the Initial Price will be set at a significant
    discount to the current market price, please revise the cover page to highlight the size of the discount and the attendant risks
    to the shareholders.

RESPONSE:
In response to the Staff’s comment, the Company has revised its disclosure on the cover page, page 3, page 10, page 31 and
page 41 of the Registration Statement.

We
also advise the Staff supplementally that on December 6, 2022, the Company publicly released information regarding its: (i) entrance
into the Collaboration and License Agreement with Akeso, Inc.; (ii) entrance into a Note Purchase Agreement and promissory notes pursuant
to which the Company agreed to sell to each of Mr. Robert W. Duggan and Dr. Maky Zanganeh unsecured promissory notes in the aggregate
amount of $520 million; and (iii) approval by the Board of a $500 million rights offering to its stockholders, including the pricing
of such rights offering (specifically including the Initial Price and Alternate Price). The disclosure of this information, including
the proposed rights offering and pricing, occurred immediately prior to the significant increase in stock price in early December referred
to above. The Company does not believe that a change to the previously disclosed terms of the Rights Offering would be fair to those
stockholders who relied on this public disclosure, and accordingly the Company does not plan to change any of the previously disclosed
information (including the pricing). This information is described on page 10 of the Registration Statement in a Q&A titled “Why
did our board of directors elect to price the Rights Offering at the lesser of the Initial Price and the Alternate Price?”

    3.
    With
    a view to disclosure and with reference to the second risk factor disclosures on pages 31 and 32, please tell us what consideration
    the Board gave to including a floor price for the offer and why it decided to include the Alternate Price feature.  Also, discuss
    what consideration, if any, given to making subscriptions revocable in the event that the stock price materially decreases during
    the offering period. Similarly tell us what steps you would take if the Board were to determine during the pendency of the offering
    to conduct a reverse stock split either during or immediately following the offering.

Division
of Corporation Finance

January
20, 2023

Page
3

RESPONSE:
Given that the Board reserves the right to terminate the Rights Offering at any time, the Special Committee and Board determined that
a floor price was not in the best interests of the Company, especially given concerns that setting a floor price can have the effect
of market forces leading to a price at the floor price. The Company believes that the Alternate Price mechanics provide subscribing stockholders
with certain protections in the event of a decline in market share price. The Company believes that inclusion of the Alternate Price
provides protection for a market price decline and has not considered making subscriptions revocable. In further response to the Staff’s
comment, the Company has revised its disclosure on page 31 of the Registration Statement.

While
the Board reserves the right to effect the reverse stock split prior to January 6, 2024, we do not intend to effect the reverse stock
split prior to the closing of the Rights Offering and issuance of shares thereunder. In accordance herewith, please see the Company’s
revised disclosure on page 32 of the Registration Statement.

  4.
  We note your statement on the cover page that
  to the extent the Alternate Price is lower than the Initial Price, you will sell additional shares of common stock. Please also revise
  your disclosure to discuss your plans if the Alternate Price were to decline such that the number of shares of common stock to be offered
  would cause you to exceed the number of authorized shares of common stock set forth in your certificate of incorporation.

RESPONSE:
In response to the Staff’s comment, the Company has revised the disclosure on the cover page and page 41 of the Registration Statement.

Please
note that the Company filed a current report on Form 8-K earlier today, and the Company has revised the disclosure in the Registration
Statement to reflect the matters disclosed in the Form 8-K.

We
believe we have been responsive to the Staff’s comments. Please direct any questions concerning this letter to the undersigned
at (212) 589-4233 or afinerman@bakerlaw.com.

Sincerely,

    Adam
    W. Finerman

    Partner

United States securities and exchange commission logo
January 12, 2023
Robert Duggan
Chairman and Chief Executive Officer
Summit Therapeutics Inc.
2882 Sand Hill Road, Suite 106
Menlo Park, CA 94025
Re:Summit Therapeutics Inc.
Registration Statement on Form S-3
Filed December 21, 2022
File No. 333-268932
Dear Robert Duggan:
            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-3
Subscription Price, page 40
1.Please revise to explain why the Board formed a Special Committee and identify the
members of that committee.
2.We note your disclosure that in determining the Subscription Price the Special Committee
considered the average price for the 30-day period prior to the filing of the preliminary
proxy statement on November 29, 2022.  With a view to disclosure and with reference to
your risk factor disclosure at the top of page 31, please tell what consideration, if any, the
Special Committee or Board has given or will give to revising the Initial Price to reflect
more recent market trading.  In this regard, we note that the stock price increased
significantly beginning in early December. To the extent that the Initial Price will be set at
a significant discount to the current market price, please revise the cover page to highlight

 FirstName LastNameRobert Duggan
 Comapany NameSummit Therapeutics Inc.
 January 12, 2023 Page 2
 FirstName LastName
Robert Duggan
Summit Therapeutics Inc.
January 12, 2023
Page 2
the size of the discount and the attendant risks to shareholders.
3.With a view to disclosure and with reference to the second risk factor disclosures on pages
31 and 32, please tell us what consideration the Board gave to including a floor price for
the offer and why it decided to include the Alternate Price feature.  Also, discuss what
consideration, if any, given to making subscriptions revocable in the event that the stock
price materially decreases during the offering period. Similarly tell us what steps you
would take if the Board were to determine during the pendency of the offering to conduct
a reverse stock split either during or immediately following the offering.
4.We note your statement on the cover page that to the extent the Alternate Price is lower
than the Initial Price, you will sell additional shares of common stock. Please also revise
your disclosure to discuss your plans if the Alternate Price were to decline such that the
number of shares of common stock to be offered would cause you to exceed the number
of authorized shares of common stock set forth in your certificate of incorporation.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact 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:       Adam Finerman, Esq.