July 7, 2025

Datuk Dr. Doris Wong Sing Ee
Chief Executive Officer
Cyclacel Pharmaceuticals, Inc.
Level 10, Tower 11, Avenue 5, The Horizon
Bangsar South City, No. 8, Jalan Kerinchi
59200, Kuala Lumpur, Malaysia

       Re: Cyclacel Pharmaceuticals, Inc.
           Draft Registration Statement on Form S-1
           Submitted June 27, 2025
           CIK No. 0001130166
Dear Datuk Dr. Doris Wong Sing Ee:

       We have conducted a limited review of your draft registration statement
and have the
following comment.

        Please respond to this letter by providing any requested information
and by publicly
filing your registration statement and non-public draft submission on EDGAR. If
you do not
believe a comment applies to your facts and circumstances or do not believe an
amendment is
appropriate, please tell us why in your response.

        After reviewing the information you provide in response to this letter
and your filed
registration statement, we may have additional comments.

Draft Registration Statement on Form S-1 submitted June 27, 2025
General

1.     We note you entered into a share exchange agreement dated May 6, 2025,
with
       FITTERS Diversified Berhad, a Malaysian publicly listed company (
Fitters Parent   )
       and FITTERS Sdn. Bhd., a Malaysia private limited company and
wholly-owned
       subsidiary of Fitters Parent (   Fitters   ) whereby Fitters Parent will
exchange all of its
       ownership interest in Fitters representing 100% of all of the issued and
outstanding
       capital shares of Fitters, for 19.99 percent of all of the issued and
outstanding shares
       of your Common Stock. We further note your disclosure that you
anticipate the
       transaction will    close in the second half of 2025.    Please provide
your analysis of
       whether you are required to include financial statements of the business
acquired
       under Rule 8-04 of Regulation S-X and the related pro forma financial
information
 July 7, 2025
Page 2

       required by Rule 8-05 of Regulation S-X. Refer to Part I, Item 11(e) of
Form S-1.
        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.

       We also remind you that your registration statement must be on file at
least two
business days prior to the requested effective date and time. Refer to Rules
460 and 461
regarding requests for acceleration. Please allow adequate time for us to
review any
amendment prior to the requested effective date of the registration statement.

       Please contact Jason Drory at 202-551-8342 or Laura Crotty at
202-551-7614 with
any other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Life
Sciences
cc:   Debbie Klis