United States securities and exchange commission logo May 29, 2024 Robert Lisicki Chief Executive Officer Zura Bio Limited 1489 W. Warm Springs Rd. #110 Henderson, NV 89014 Re: Zura Bio Limited Registration Statement on Form S-1 Filed May 24, 2024 File No. 333-279719 Dear Robert Lisicki: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Alan Campbell at 202-551-4224 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Brandon Fenn