Exhibit 99.1

[GYROSCOPE LETTERHEAD]

February 19, 2021

Securities and Exchange Commission

Division of Corporation Finance

Office of the Chief Accountant

100 F Street NE

Washington, DC 20549

Re: Gyroscope Therapeutics Holdings Ltd

Registration Statement on Form F-1

Filed January 15, 2021

CIK No. 0001837620

Application for Waiver of Requirements of Form 20-F, Item 8.A.4

Ladies and Gentlemen:

I am Senior Vice President, Finance, of Gyroscope Therapeutics Holdings Ltd, a private limited company incorporated under the laws of England and Wales (to be re-registered as a public limited company and re-named Gyroscope Therapeutics Holdings plc) (the “Company”). In connection with a proposed initial public offering of the Company’s American Depositary Shares (“ADSs”), each ADS representing the right to receive one ordinary share of the Company, we hereby respectfully request that the U.S. Securities and Exchange Commission (the “Commission”) waive the requirement of Item 8.A.4 of Form 20-F, which states that in the case of a company’s initial public offering (“IPO”), the Registration Statement on Form F-1 must contain audited financial statements of a date not older than 12 months from the date of the offering unless a waiver is obtained. See also Division of Corporation Finance, Financial Reporting Manual, Section 6220.3.

Because the Company’s audited financial statements for the year ended December 31, 2020 will not be available until approximately March 5, 2021, at the time of the submission by the Company to the Commission of its Amendment No. 1 to the Draft Registration Statement on Form F-1 on February 19, 2021 (the “Confidential Amendment No. 1”), the Company’s Confidential Amendment No. 1 satisfied Item 8.A.4 of Form 20-F, which is applicable to Confidential Amendment No. 1 pursuant to Item 4(a) of Form F-1, because it contained audited financial statements for the year ended January 31, 2020 prepared in accordance with generally accepted accounting principles in the United States.

The Company is submitting this waiver request pursuant to Instruction 2 to Item 8.A.4 of Form 20-F, which provides that the Commission will waive the 12-month age of financial statements requirement “in cases where the company is able to represent adequately to us that it is not required to comply with this requirement in any other jurisdiction outside the United States and that complying with this requirement is impracticable or involves undue hardship.”

See also the Commission’s November 1, 2004 release entitled International Reporting and Disclosure Issues in the Division of Corporation Finance (available on the Commission’s website at http://www.sec.gov/divisions/corpfin/internatl/cfirdissues1104.htm) at Section III.B.c, in which the Commission notes:

“the instruction indicates that the staff will waive the 12-month requirement where it is not applicable in the registrant’s other filing jurisdictions and is impracticable or involves undue hardship. As a result, we expect that the vast majority of IPOs will be subject only to the 15-month rule. The only times that we anticipate audited financial statements will be filed under the 12-month rule are when the registrant must comply with the rule in another jurisdiction, or when those audited financial statements are otherwise readily available.”

In connection with this request, on behalf of the Company, I represent to the Commission that:

1. The Company is not currently a public reporting company in any other jurisdiction.

2. The Company is not required by any jurisdiction outside the United States to prepare, and has not prepared, financial statements audited under any generally accepted auditing standards for any interim period.

3. Compliance with Item 8.A.4 is impracticable and involves undue hardship for the Company.

4. The Company does not anticipate that its audited financial statements for the year ended December 31, 2020 will be available until approximately March 5, 2021.

5. In no event will the Company seek effectiveness of the Registration Statement if its audited financial statements are older than 15 months at the time of the offering.

We are filing this letter as an exhibit to Confidential Amendment No. 1 pursuant to Instruction 2 to Item 8.A.4 of Form 20-F.

Please do not hesitate to contact Yasin Keshvargar of Davis Polk & Wardwell LLP at 1 212 450 4839 if you have any questions regarding the foregoing or if we can provide any additional information.

Very truly yours,

/s/ Andrew Prosser

Andrew Prosser

Senior Vice President, Finance