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                             August 21, 2020

       Alan Hirzel
       Chief Executive Officer
       Abcam plc
       Discovery Drive
       Cambridge Biomedical Campus
       Cambridge, CB2 0AX
       United Kingdom

                                                        Re: Abcam plc
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted July 23,
2020
                                                            CIK No. 0001492074

       Dear Mr. Hirzel:

              We have reviewed your draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Draft Registration Statement on Form F-1

       Prospectus Summary
       Overview, page 1

   1.                                                   Please tell us whether
you commissioned any of the market and industry data presented in
                                                        the prospectus and, if
so, file a consent for the use of such data. Also, revise your
                                                        disclosure to cite
specific support for the statistical data referenced in this section and
                                                        throughout the
prospectus, including for statements currently referenced as having support
                                                        from    industry data
 or    industry sources.
 Alan Hirzel
FirstName
Abcam plc LastNameAlan Hirzel
Comapany
August 21, NameAbcam
           2020        plc
August
Page 2 21, 2020 Page 2
FirstName LastName
2.       Please disclose the basis for the following statement from page 3:
For example,
         our award winning knockout CRISPR gene editing program is one of the
most accepted
         and trusted validation processes for antibody specificity and is the
largest of its kind in the
         industry.    In particular, please provide support for the "award
winning and "largest of its
         kind" claims.

Our Competitive Strengths, page 5

3.       Please revise to provide a clear definition of what constitutes a
session on your website.
         Disclose, as applicable, whether estimates or assumptions underlie the
metric or its
         calculation. Clarify how this metric is useful to investors and how
management uses it.
         For instance, please discuss, as applicable, whether/how the monthly
volume of sessions
         impacted your sales during the 12-month period you reference. Also
tell us whether you
         have historical data beyond 12 months and, if so, whether this data
shows the same or
         different trends.
4.       Please briefly explain the significance of "appearing first" in a web
search and identify the
         competitor that you reference. Tell us whether you engage in paid
advertisements or other
         activities that might result in your products appearing earlier in a
search. Also tell us, if
         known, whether your sales for these 10,000 products is correspondingly
greater than the
         referenced competitor.
5.       With reference to your disclosure on page 28, please revise the
Summary to explain
         briefly why growth in citations reflects influence within the research
community.
Risk Factors, page 7

6.       With reference to your disclosures on pages 19 and 71, please revise
your disclosure in the
         first bullet point on page 7, or elsewhere in the Summary, as
applicable, to clarify
         that COVID-19 has adversely impacted your business operations and
results. Briefly
         discuss the impact(s).
Summary of Consolidated Financial and Other Data
Non IFRS Financial Measures, page 12

7.       You present free cash flow as a measure of your operating performance.
Given that "free
         cash flow" is widely understood to be a liquidity measure, there is a
concern that investors
         may not fully understand your basis for characterizing this non-IFRS
measure as a
         performance measure. Also, the use of the words "cash flow" in the
measure's title is
         confusingly similar to the IFRS financial measures included in the
Statements of Cash
         Flows. Further, we note your definition of this measure as starting
with IFRS cash flow
         provided by operating activities. If you maintain that free cash flow
is an operating
         performance measure in addition to a liquidity measure, then please
explainwhy this
         measure is useful to investors as an operating performance measure in
accordance with
         Item 10(e)(1)(i)(c) of Regulation S-K. Please also provide a
reconciliation from net
 Alan Hirzel
Abcam plc
August 21, 2020
Page 3
         income in accordance with Item 10(e)(1)(i)(b) of Regulation S-K.
Risk Factors
Risks Relating to our Business and Industry, page 23

8.       Please reconcile your disclosure on page 102 that 44% of your FY2019
revenue came
         from the United States and your disclosure on page 29 that 62% of your
FY2019 came
         from outside the United States.
Management   s Discussion and Analysis of Financial Condition and Results of
Operations
Impact of COVID-19 Pandemic, page 71

9.       We note that on page F-42 you indicate that the consolidated group
drew on a revolving
         credit facility to ensure adequate available funds through the
COVID-19 disruption.
         Please revise to disclose this drawdown and discuss any other funding
sources sought as a
         result of COVID-19.
Application of Significant Accounting Policies
Impairment of Our ERP System, page 80

10.      We note your disclosure that as a result of a review that was
undertaken of historical
         expenditure incurred to date as part of the impairment review of
assets under construction,
         two impairment indicators were identified which resulted in the
recognition of an
         impairment of   12.8 million related to the ERP system. Given the
application and
         identification of amounts in connection with the impairment of your
ERP system is
         considered a critical accounting estimate, please expand your
disclosures to highlight
         some of the significant assumptions that were used along with the
uncertainties involved
         in applying any of the principles. Please ensure your disclosures
highlight how these items
         may have different effects on financial results, including why these
items are subject to
         change and their sensitivity to change. Finally please tell us your
consideration of
         including the disclosure requirements in paragraph 130 (e) through (g)
of IAS 36.
Quantitative and Qualitative Disclosure about Market Risk, page 82

11.      On page 82 you disclose that you are exposed to a variety of risks,
including interest rate
         risk, which you discuss in this section of the document. Please revise
to include this
         discussion or advise.
Our  MarketLastNameAlan
FirstName    Opportunities, Hirzel
                               page 94
Comapany
12.         NameAbcam
       For figure  4, pleaseplcexplain how this graph showing worldwide total
pharmaceutical R&D
Augustspend   relates
        21, 2020  Pageto 3your specific statements about the increasing market
for biological drugs.
FirstName LastName
 Alan Hirzel
FirstName
Abcam plc LastNameAlan Hirzel
Comapany
August 21, NameAbcam
           2020        plc
August
Page 4 21, 2020 Page 4
FirstName LastName
Customers, page 102

13.      Please revise to discuss how the "transactional Net Promoter Score
(tNPS)" measures
         satisfaction. Also clarify whether this is a proprietary metric and,
if so, how it is
         calculated. Also, revise to place your 56.2% score into context.
Intellectual Property, page 103

14.      Please revise to disclose the material terms of your license
agreements with MIT and
         Spring Bio. Also, file these licenses as exhibits or advise.
Principal Shareholders, page 123

15.      Please revise your disclosure to identify the natural person or
persons who have voting
         and investment control of the shares held by Durable Capital Partners
and Harding
         Loevner LLC.
Related Party Transactions, page 125

16.      Please include a brief description of the organizational structure of
your group and your
         position within the group. Refer to Item 4(C) of Form 20-F.
Description of Share Capital and Articles of Association, page 126

17.      Please revise to provide all information required by Item 10(A) of
Form 20-F or advise.
Differences in Corporate Law, page 138

18.      We note that you refer shareholders to applicable Delaware and English
law. It is not
         appropriate to qualify your disclosure by reference to information
that is not included in
         the filing or filed as an exhibit. Please revise accordingly.
3. Principal Accounting Policies
Intangible Assets, page F-11

19.      Please further expand your policy to disclose when you typically begin
amortization of
         intangible assets under construction for software and internally
developed technology . In
         that regard, your disclosures should highlight when you typically view
such assets to be in
         the location and condition necessary for them to be capable of
operating in the manner
         intended by management consistent with paragraph 97 of IAS 38.
Revenue Recognition, page F-11

20.      For each of the Catalogue, Custom Products and Services, IVD and
Royalties and License
         Revenue streams, expand your disclosures consistent with the
requirements in IFRS
         15 and considering the appropriate level of detail based on
materiality to provide
         company-specific information for:
 Alan Hirzel
Abcam plc
August 21, 2020
Page 5
                The nature of the goods and services that you have promised to
transfer. See
              paragraph 119 of IFRS 15
                The performance obligation(s) you have determined from your
contracts with
              customers. For each performance obligation highlight whether you
have bundled any
              goods or services that are not considered distinct pursuant to
paragraphs 26 through
              30 of IFRS 15;
                Your typical payment terms for your performance obligations.
See paragraph 119 of
              IFRS 15;
                The timing of when you recognize revenue (i.e., point in time
or over time). To the
              extent you are recognizing revenue over time, please provide an
explanation of the
              type of method used to recognize revenue and why such a method
was chosen. See
              paragraph 124 of IFRS 15;
                Provide disclosures for each type of variable consideration
included in the transaction
              price and the significant judgments used. See paragraph 126 of
IFRS 15; and
                If material, the amount of any contract assets and liabilities
that result from your
              arrangement. See paragraph 116 through 118 of IFRS 15.
General

21.      Please supplementally provide us with copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
         not they retain copies of the communications.
        You may contact Ameen Hamady at (202) 551-3891 or Terence O'Brien at
(202) 551-
3355 if you have questions regarding comments on the financial statements and
related
matters. Please contact Margaret Schwartz at (202) 551-7153 or Joseph McCann at
(202) 551-
6262 with any other questions.



FirstName LastNameAlan Hirzel                                  Sincerely,
Comapany NameAbcam plc
                                                               Division of
Corporation Finance
August 21, 2020 Page 5                                         Office of Life
Sciences
FirstName LastName