April 10, 2025

Andrew Guggenhime
President and Chief Financial Officer
Vaxcyte, Inc.
825 Industrial Road, Suite 300
San Carlos, California 94070

        Re: Vaxcyte, Inc.
            Form 10-K for the fiscal year ended December 31, 2024
            Filed February 25, 2025
            File No. 001-39323
Dear Andrew Guggenhime:

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

       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
our 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 99
Results of Operations, page 109

1.
       You disclose on page 106 that do not allocate all of your costs by
vaccine candidates,
       as your research and development expenses include internal costs, such
as payroll and
       other personnel expenses, which are not tracked by vaccine candidate.
Please provide
       revised disclosure to be included in future filings to address the
following:

             Clarify which expenses you do allocate by project and clarify if
you track any
           expenses by candidate. To the extent you do track any research and
development
           expenses by program, provide a breakdown of the expenses tracked by
project.
             If you do not track external expenses by program, break out
external research and
           development costs by clinical and preclinical. If you cannot
disaggregate these
 April 10, 2025
Page 2

           amounts, please disclose that fact and explain why not.
             For all other research and development expenses. provide us with
other
           quantitative or qualitative disclosure that provides more
transparency as to the
           type of research and development expenses incurred (i.e. by nature
or type of
           expense) which should reconcile to total research and development
expense on the
           Statements of Operations. We note that you included a break out of
research and
           development expenses by type in the 10-K for the year ended December
31, 2023.


        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 Vanessa Robertson at
202-551-3649 with
any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Life
Sciences