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                              December 8, 2020

       Jay Short, Ph.D.
       Chairman and Chief Executive Officer
       BioAtla, Inc.
       11085 Torreyana Road
       San Diego, CA 92121

                                                        Re: BioAtla, Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed December 8,
2020
                                                            File No. 333-250093

       Dear Dr. Short:

             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
December 3, 2020 letter.

       Amendment No. 1 to Registration Statement on Form S-1

       Capitalization, page 86

   1.                                                   As you have noted
elsewhere throughout the filing that certain of your stockholders have
                                                        elected to convert
their Series D preferred stock into shares of Class B common stock,
                                                        instead of common
stock, upon the completion of this offering, please tell us why, on a
                                                        pro forma basis, you do
not reflect the issuance of shares of your Class B common stock.
       Global Co-Development and Collaboration Agreement with BeiGene, Ltd.,
page 160

   2.                                                   We note your disclosure
that you are eligible to receive tiered royalties, ranging from the
                                                        high-single digits to
low twenties. Please revise your disclosure to state the number of
                                                        tiers under your
royalty arrangement.
 Jay Short, Ph.D.
BioAtla, Inc.
December 8, 2020
Page 2
Amended and Restated Exclusive Rights Agreement with Himalaya Therapeutics
SEZC, page
161

3.    We note your disclosure that payments to the Company may include
double-digit
      royalties. Please expand your disclosure to provide a more defined range
of royalties that
      does not exceed ten percentage points.
       You may contact Nudrat Salik at 202-551-3692 or Sasha Parikh at
202-551-3627 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Deanna Virginio at 202-551-4530 or Suzanne Hayes at 202-551-3675 with
any other
questions.



                                                           Sincerely,
FirstName LastNameJay Short, Ph.D.
                                                           Division of
Corporation Finance
Comapany NameBioAtla, Inc.
                                                           Office of Life
Sciences
December 8, 2020 Page 2
cc:       David Shulman, Esq.
FirstName LastName