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                              August 17, 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. 2 to
Registration Statement on Form S-1
                                                            Filed August 11,
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 July
28, 2023 letter.

       Amendment No. 2 to Registration Statement on Form S-1

       Cover Page

   1.                                                   We note from your
revisions in response to prior comment 1 that you have added the
                                                        resale of 3,782,000
Pre-Funded Warrants to the headings on the cover page. However, we
                                                        continue to note that
resale of the Pre-Funded Warrants do not appear to be otherwise
                                                        included in your cover
page and do not appear to be addressed in your disclosure
                                                        throughout the filing
such as under the "The Offering" section starting on page 14, the
                                                        "Description of
Securities" section starting on page 134, the "Plan of Distribution" section
                                                        starting on page 141,
and the "Selling Securityholders" starting on page 128. Please
                                                        revise as appropriate.
 Someit Sidhu, M.D.
FirstName LastNameSomeit Sidhu, M.D.
Zura Bio Limited
Comapany
August 17, NameZura
           2023      Bio Limited
August
Page 2 17, 2023 Page 2
FirstName LastName
2.       Please tell us where the 3,782,000 Class A Ordinary Shares issuable
upon the exercise of
         the Pre-Funded Warrants appears in your filing fee table.
Selling Securityholders, page 128

3.       Please tell us how the number of Class A ordinary shares indicated in
the first bullet point
         reconciles to the number of Class A ordinary shares indicated on the
cover page or revise
         as appropriate.
4.       We note that you indicate on page 130 that the total number of Class A
ordinary shares
         being offered for resale by the selling security holders is
39,943,124. From your cover
         page, it appears that you are registering 46,843,120 Class A ordinary
shares for resale.
         Please reconcile your disclosure.
5.       As noted above, there does not appear to be a selling securityholder
table related to
         the resale of the 3,782,000 Pre-Funded Warrants. Please revise as
appropriate.
       Please contact Dillon Hagius at 202-551-7967 or Tim Buchmiller at
202-551-3635 with
any questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Life
Sciences
cc:      Giovanni Caruso, Esq.