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VIA EDGAR AND HAND DELIVERY

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-6010


Attention:		Ameen Hamady Terence O’Brien Margaret Schwartz Joseph McCann

Re:		Abcam plc Registration Statement on Form F-1 File No. 333-249263

Ladies and Gentlemen:

On behalf of Abcam plc (the “Company”), set forth below is the Company’s response to the comment letter received from the Staff of the Division of Corporate Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) on October 20, 2020 with respect to the Company’s Registration Statement on Form F-1 filed on October 2, 2020 (as amended by Amendment No. 1 filed on October 19, 2020, the “Registration Statement”). This letter is being filed with Amendment No. 2 to the Registration Statement (“Amendment No. 2”).

For ease of review, we have set forth below the numbered comment of your letter in bold type followed by the Company’s response thereto. Unless otherwise indicated, capitalized terms used herein have the meanings to be assigned to them in the Amendment No. 2.

Exhibits

We refer to the legal opinion filed as Exhibit 5.1. Please have counsel revise to delete assumptions (k), (l) and (m) in schedule 1 or explain to us why these assumptions are appropriate. Also have counsel revise the limitations on reliance in section 4 of the opinion to avoid the implication that purchasers in the offering are not entitled to rely on the opinion. For guidance, please refer to Staff Legal Bulletin No. 19 Sections II.B.3.a and II.B.3.d, respectively.