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                              October 17, 2022

       Jordan Licht
       Chief Financial Officer
       Burford Capital Limited
       Oak House
       Hirzel Street
       St. Peter Port GY1 2NP
       Guernsey

                                                        Re: Burford Capital
Limited
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2021
                                                            Filed March 29,
2022
                                                            File No. 001-39511

       Dear Jordan Licht:

              We have reviewed your July 25, 2022 response to our comment
letter 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 these comments 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
       comments apply to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       June 27, 2022 letter.

       Form 20-F for the Fiscal Year Ended December 31, 2021

       Consolidated statements of cash flows, page 80

   1.                                                   We acknowledge your
response to prior comment 1 and our discussion on October 4,
                                                        2022. Once you fund a
capital provision asset, please describe for us any role you play in
                                                        managing capital
provision assets until settlement. As part of your response, describe the
                                                        circumstances under
which you have decision making ability over the litigation activities
                                                        and costs incurred to
support the matter.
   2.                                                   We note in your cash
flows from operating activities you include a subtotal for net cash
                                                        provided by/(used in)
operating activities before funding of capital provision assets and
 Jordan Licht
FirstName LastNameJordan   Licht
Burford Capital Limited
Comapany
October 17,NameBurford
            2022        Capital Limited
October
Page 2 17, 2022 Page 2
FirstName LastName
         net (funding of)/proceeds from marketable securities. Please tell us
why you believe
         presenting a total other than net cash provided by (used in) operating
activities is
         consistent with the Form and Content guidance provided in ASC Subtopic
230-10-45.
         Tell us how you concluded this was not a non-GAAP financial measure,
which would be
         prohibited from inclusion in the financial statements under Item
10(e)(1)(ii)(C) of
         Regulation S-K.
Note 2: Summary of significant accounting policies
Fair value hieracrchy
Valuation processes
Valuation methodology for Level 3 investments, page 85

3.       ASC Topic 820 defines market participant as a buyer that is
knowledgeable, having a
         reasonable understanding about the asset and the transaction using all
available
         information that might be obtained through due diligence efforts that
are usual and
         customary. As it relates to the valuation of your capital provision
assets, please tell us:
             the information you obtain and consider as part of your due
diligence process to
             determine the amount you will agree to pay to acquire contractual
rights to litigation
             settlements or amounts receivable under court judgments;
             the information you obtain and consider as part of your due
diligence process to
             determine whether you should increase the amount you pay to
acquire additional
             contractual rights to litigation settlements or amounts receivable
under court
             judgments for cases (or pools of cases) in which you already have
investments;
             whether you believe gathering and considering the information you
consider would
             not be usual and customary for a knowledgeable party to obtain to
have a reasonable
             understanding of the price that party would pay to acquire the
right under the
             contracts you enter into, and if not why not; and
             whether you view yourself as a market participant, and if not why
not.

4.       ASC 820-10-35 requires that the fair value measurement as of the
reporting date use the
         assumptions that a market participant would use in pricing the assets,
acting in their
         economic best interest. In your period end fair value measurements of
your capital
         provision assets, please describe all of the significant observable
and unobservable inputs
         that you assume a market participant would use to estimate the price
they would pay as of
         that date for your capital provision assets. If you do not base your
assumed market
         participant assumptions on relevant data available to you, tell us why
you believe not
         incorporating this data is consistent with the guidance in ASC
820-10-35-54A that states
         that,    A reporting entity shall develop unobservable inputs using
the best information
         available in the circumstances, which might include the reporting
entity's own data.
5.       ASC 820-10-35-24A describes three valuation approaches, the market
approach, cost
         approach, and income approach. Please tells us whether the valuation
technique you use
         to fair value your capital provision assets is consistent with one or
more of these
 Jordan Licht
Burford Capital Limited
October 17, 2022
Page 3
         approaches, and if so the basis for your determination. If you used an
income approach,
         please clarify how you specifically considered the expected timing of
payments in
         applying the guidance in ASC 820-10 55-3F which states:    The income
approach converts
         future amounts (for example, cash flows or income and expenses) to a
single current (that
         is, discounted) amount.
6.       Please tell us whether you consider the price you pay to acquire a
capital provision asset
         to be fair value, and if so how you calibrate your valuation
technique, consistent with the
         guidance in ASC 820-10-35-24C, such that the initial recognition of
your valuation
         technique equals your transaction price.

        You may contact Mark Brunhofer at 1-202-551-3638 or Sharon Blume at
1-202-551-
3474 if you have any questions.



FirstName LastNameJordan Licht                                 Sincerely,
Comapany NameBurford Capital Limited
                                                               Division of
Corporation Finance
October 17, 2022 Page 3                                        Office of
Finance
FirstName LastName