August 23, 2019

George Scangos, Ph.D.
President and Chief Executive Officer
Vir Biotechnology, Inc.
499 Illinois Street, Suite 500
San Francisco, California 94158

       Re: Vir Biotechnology, Inc.
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted August 7, 2019
           CIK No. 0001706431

Dear Dr. Scangos:

      We have reviewed your amended draft registration statement and have the
following
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment No. 1 to Draft Registration Statement on Form S-1 submitted August 7,
2019

Prospectus Summary
Our Development Pipeline, page 2

1.     We note your revisions in response to our prior comment 8. Please also
revise your
       description of the initial data from the clinical study of VIR-2218 in
the Summary to
       disclose the number of patients that have received VIR-2218 as a
treatment. In addition,
       please revise your description of the initial data throughout the
prospectus to disclose not
       only the reduction in HBsAg, but the baseline levels of HBsAg in treated
patients, since
       the FDA accepts levels of HBsAg less than 0.05 IU/ml as demonstrating a
functional
       cure.
 George Scangos, Ph.D.
FirstName LastNameGeorge Scangos, Ph.D.
Vir Biotechnology, Inc.
Comapany NameVir Biotechnology, Inc.
August 23, 2019
Page 2
August 23, 2019 Page 2
FirstName LastName
Business
Our Corporate History, page 96

2.       We note your response to our prior comment 6. Since you are not
involved in the clinical
         development of mAb114 and you determined not to pursue a sublicense
opportunity to
         develop mAb114 in collaboration with the NIH , please remove from your
corporate
         timelines on pages 76 and 96 the start of Phase 2/3 clinical trials
for mAb114. We would
         not object to including a marker in the timeline for when mAb114 was
identified with
         additional disclosure regarding your collaboration with the NIH.
       You may contact Ibolya Ignat at 202-551-3636 or Angela Connell at
202-551-3426 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Irene Paik at 202-551-6553 or Mary Beth Breslin at 202-551-3625 with
any other
questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Healthcare & Insurance
cc:      Laura Berezin - Cooley LLP