May 8, 2025

Verender Badial
Chief Financial Officer
Zura Bio Limited
1489 W. Warm Springs Rd. #110
Henderson, NV 89014

       Re: Zura Bio Limited
           Form 10-K for the fiscal year ended December 31, 2024
           Filed March 25, 2025
           File No. 001-40598
Dear Verender Badial:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       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.

Form 10-K for the fiscal year ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations,
page 86
Results of Operations, page 95

1.     We note from the research and development (R&D) expenses critical
accounting
       estimate on page 101 your statement that you allocate external costs by
program and
       functional area and that internal costs are not allocated by program
because these
       costs are deployed across multiple programs. Please revise your
disclosure in future
       filings beginning with your Form 10-Q for the period ended March 31,
2025 to
       provide a breakout of external R&D expenses by program and functional
area or
       indication, as well as internal costs by function, type or category,
along with a
       discussion of the factor(s) impacting the changes in the amounts for the
periods
       presented. We note this information is particularly relevant to
investors as your three
       candidates are being evaluated to address multiple indications and given
you plan to
       substantially increase R&D expenses for the foreseeable future as you
develop your
 May 8, 2025
Page 2

       product candidates and manufacturing processes and conduct discovery and
research
       activities for your clinical programs (see page 93). As part of your
response, please
       provide what this disclosure would have looked like had it been included
in your
       December 31, 2024 Form 10-K.
6. License Agreements, page F-15
WuXi Biologics License, page F-18

2.     We note the discussion of the Cell Line License Agreement hereunder as
well as
       the WuXi Biologics MSA disclosed on page 100. Please tell us and revise
future
       filings to disclose the extent to which consideration was exchanged in
order to enter
       into the WuXi Biologics MSA or subsequently pursuant to the agreement.
Please
       either file both of these agreements as exhibits in your next periodic
filing pursuant to
       Item 601(b)(10)(ii)(B) of Regulation S-K, or tell us why they are not
required to be
       filed.
        In closing, 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 Jenn Do at 202-551-3743 or Kevin Vaughn at 202-551-3494
with any
questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Life
Sciences