September 25, 2024 Mark DyBul Chief Executive Officer Renovaro Biosciences Inc. 2080 Century Park East, Suite 906 Los Angeles, CA 90067 Re: Renovaro Biosciences Inc. Form 10-K for the Fiscal Year Ended June 30, 2023 Filed October 2, 2023 File No. 001-38758 Dear Mark DyBul: We have reviewed your August 15, 2024 response to our comment letter and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our July 12, 2024 letter. Form 10-K for the Fiscal Year Ended June 30, 2023 Notes to the Consolidated Financial Statements Note 4 - Intangible Assets and Goodwill, page F-14 1. Please provide us with the results of your annual goodwill impairment assessment as of June 30, 2024 as it relates to the goodwill recognized in the February 2024 acquisition of GEDiCube. Please explain how the significant decline in your market capitalization since the acquisition date factored into your analysis. September 25, 2024 Page 2 Please contact Frank Wyman at 202-551-3660 or Angela Connell at 202-551-3426 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Life Sciences