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                            July 28, 2023

       Someit Sidhu, M.D.
       Chief Executive Officer
       Zura Bio Limited
       4225 Executive Square, Suite 600
       La Jolla, CA 92037

                                                        Re: Zura Bio Limited
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed July 21, 2023
                                                            File No. 333-272628

       Dear Someit Sidhu:

             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 June
23, 2023 letter.

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

       Cover Page

   1.                                                   Please revise the cover
page heading to quantify the number of each type of security being
                                                        registered. Ensure that
this revision includes:
                                                            the number of Class
A Ordinary Shares;
                                                            the number of
Warrants;
                                                            the number of
Prefunded Warrants;
                                                            the number of Class
A Ordinary Shares underlying the Warrants;
                                                            the number of Class
A Ordinary Shares underlying the Prefunded Warrants.
                                                        In this regard, we note
from the filing fee table that you are registering the resale of
                                                        3,782,000 Class A
Ordinary Shares underlying 3,782,000 pre-funded warrants to purchase
 Someit Sidhu, M.D.
Zura Bio Limited
July 28, 2023
Page 2
       Class A Ordinary Shares, and the resale of 3,782,000 Pre-Funded
Warrants, neither of
       which appears to be included in your cover page heading, and with
respect to the resale of
       the Pre-Funded Warrants your other disclosure. Please revise as
appropriate.
2.     We note your response to comment 2 and re-issue in part. As your
warrants are out of the
       money, and, as you disclose on the cover page, "it is unlikely that the
Private Placement
       Warrants or Public Warrants are exercised unless the trading price of
ordinary shares
       increases to above the exercise price[,]" please describe on the cover
page the impact on
       your liquidity and update the discussion on the ability of your company
to fund your
       operations on a prospective basis with your current cash on hand. To the
extent not
       already included, please ensure this disclosure is also included in the
prospectus summary,
       risk factors, MD&A, and use of proceeds sections.
If certain holders of our Class A Ordinary Shares sell a significant portion of
their securities, it
may negatively impact..., page 57

3.     We note your response to comment 4 and re-issue in part. Please disclose
what
       percentage the securities being registered for resale represent of the
total number of shares
       outstanding.
General

4.     We note your response to comment 8 and re-issue in part. Please revise
your prospectus
       to:
           disclose that while the sponsor, private placement investors, PIPE
investors, or other
           selling securityholders may experience a positive rate of return
based on the current
           trading price, the public securityholders may not experience a
similar rate of return
           on the securities they purchased due to differences in the purchase
prices and the
           current trading price;
           disclose the potential profit the selling securityholders will earn
based on the current
           trading price; and
           include appropriate risk factor disclosure about these
aforementioned subjects.

       Please contact Dillon Hagius at 202-551-7967 or Tim Buchmiller at
202-551-3635 with
any questions.



                                                               Sincerely,
FirstName LastNameSomeit Sidhu, M.D.
                                                               Division of
Corporation Finance
Comapany NameZura Bio Limited
                                                               Office of Life
Sciences
July 28, 2023 Page 2
cc:       Giovanni Caruso, Esq.
FirstName LastName