November 7, 2019

William V. Williams
Chief Executive Officer
BriaCell Therapeutics Corp.
Suite 300   235 West 15th Street
West Vancouver, BC V7T 2X1

       Re: BriaCell Therapeutics Corp.
           Registration Statement on Form F-1
           Filed October 22, 2019
           File No. 333-234292

Dear Dr. Williams:

       We have reviewed your 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 amending your registration statement
and providing the
requested information. 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 any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our September
26, 2019 letter.

Registration Statement on Form F-1 filed October 22, 2019

Prospectus Summary
Overview of the Company, page 5

1.     We note your revisions in response to prior comment 3; however, your
revised Summary
       presentation includes graphics concerning proposed mechanisms of action
that are highly
       detailed, reliant on complex scientific terminology, and repetitive of
graphics presented in
       your Business section. Accordingly, please revise your Summary
presentation to remove
       these graphics or advise.
2.     We note your revisions in response to prior comment 4. Your disclosure
in the seventh
       paragraph on page 5 indicates that your development work is now focused
on a
       combination therapy involving your product and Incyte Corporation's PD-1
inhibitor
 William V. Williams
FirstName LastNameWilliam V. Williams
BriaCell Therapeutics Corp.
Comapany 7, 2019
November NameBriaCell Therapeutics Corp.
November 7, 2019 Page 2
Page 2
FirstName LastName
         pursuant to a collaboration and supply agreement. If so, please revise
the third and
         seventh paragraphs on page 5 to remove references to Keytruda and
Merck. To the extent
         that you are actively pursuing development of a combination therapy
using Keytruda and
         wish to highlight it in your Summary, the Summary should clarify
whether you have a
         license and/or collaboration/supply agreement with Merck, or whether
you will need such
         agreement(s) to commercialize a combination therapy using Keytruda.

Products/Pipeline, page 5

3.       We note that you will need to complete your Phase I/IIa study and
additional clinical
         studies before the FDA determines whether your product candidate will
be approved for
         commercial sale. Please revise your disclosure to discuss the
additional clinical studies
         that will need to be completed prior to submitting a Biologics License
Application.
Description of Business
Manufacturing, page 72

4.       We note your response to our prior comment 32. Please also expand your
disclosure on
         page 72 to discuss the termination provisions of each agreement. In
addition, please refile
         Exhibit 10.9 to include Attachments One and Two.
Government Regulation, page 72

5.       We note your revised disclosure on page 74 that in some cases, FDA
will grant
         preliminary marketing authorization for drugs treating areas of unmet
medical need based
         on Phase 2 clinical trials and that in this case, they will also
require confirmatory Phase 3
         evaluation post-marketing. Please revise your disclosure to clarify
whether you will need
         to complete Phase 3 clinical trials prior to submitting your marketing
application and to
         describe what the Phase 3 evaluation post-marketing will entail.
Material Agreements, page 122

6.       We note that many of your material agreements relate to conducting
clinical studies of a
         product candidate called BriaVaxTM. Please tell us the significance of
BriaVaxTM to your
         business operations and why there is no disclosure relating to it in
the discussion of your
         product candidates.
        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.

       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.
 William V. Williams
BriaCell Therapeutics Corp.
November 7, 2019
Page 3

        You may contact Franklin Wyman at (202) 551-3660 or Lisa Vanjoske at
(202) 551-3614
if you have questions regarding comments on the financial statements and
related matters. Please
contact Irene Paik at (202) 551-6553 or Joseph McCann at (202) 551-6262 with
any other
questions.



                                                           Sincerely,
FirstName LastNameWilliam V. Williams
                                                           Division of
Corporation Finance
Comapany NameBriaCell Therapeutics Corp.
                                                           Office of Life
Sciences
November 7, 2019 Page 3
cc:       Avital Perlman
FirstName LastName