March 15, 2019

David Giljohann
Chief Executive Officer
Exicure, Inc.
8045 Lamon Avenue
Suite 410
Skokie, IL 60077

       Re: Exicure, Inc.
           Registration Statement on Form S-3
           Filed March 8, 2019
           File No. 333-230175

Dear Dr. Giljohann:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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.

Registration Statement on Form S-3

Description of Capital Stock
Anti-Takeover Effects of Provisions of Our Charter Documents, page 15

1.     We refer to your disclosure in the second full paragraph on page 16 that
your charter
       provides that the Delaware Court of Chancery will be the exclusive forum
for any
       derivative action. Please disclose whether this provision applies to
actions arising under
       the Securities Act or Exchange Act. In that regard, we note that Section
27 of the
       Exchange Act creates exclusive federal jurisdiction over all suits
brought to enforce any
       duty or liability created by the Exchange Act or the rules and
regulations thereunder, and
       Section 22 of the Securities Act creates concurrent jurisdiction for
federal and state courts
       over all suits brought to enforce any duty or liability created by the
Securities Act or the
 David Giljohann
Exicure, Inc.
March 15, 2019
Page 2
      rules and regulations thereunder. If the provision applies to claims
arising under the
      Securities Act, also disclose that there is uncertainty with respect to
whether a court would
      enforce this provision, and that stockholders will not be deemed to have
waived
      your compliance with the federal securities laws and the rules and
regulations thereunder.
General

2.    We note that you incorporate by reference your Form 10-K for the fiscal
year
      ended December 31, 2018; however, the Form 10-K incorporates by reference
information
      from your definitive proxy statement that has not yet been filed. Please
note that we will
      not be in a position to accelerate the effective date of your
registration statement until you
      have amended the Form 10-K to include Part III information or filed the
definitive proxy
      statement. Please refer to Compliance and Disclosure Interpretations,
Securities Act
      Forms Question 123.01 and Regulation S-K Question 117.05 for guidance.
        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.

       Please contact Dorrie Yale at 202-551-8776 or Suzanne Hayes at
202-551-3675 with any
questions.



                                                             Sincerely,
FirstName LastNameDavid Giljohann
                                                             Division of
Corporation Finance
Comapany NameExicure, Inc.
                                                             Office of
Healthcare & Insurance
March 15, 2019 Page 2
cc:       Deepa Rich, Esq.
FirstName LastName