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                           January 12, 2023

       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 December 2, 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
       October 17, 2022 letter.

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

       Note 2: Summary of significant accounting policies
       Fair value hierarchy
       Valuation processes
       Valuation methodology for Level 3 investments, page 85

   1.                                                   We acknowledge your
response to prior comment 5 and our discussion on January 4, 2023
                                                        where you stated your
valuation approach is consistent with the principles of the income
                                                        approach, as described
in ASC 820-10-35-24A. As it relates to the initial valuation of
                                                        your capital provision
assets, please respond to the following:
                                                            Tell us whether
when determining the terms you are willing to offer for contractual
 Jordan Licht
FirstName  LastNameJordan  Licht
Burford Capital Limited
Comapany
January 12,NameBurford
            2023        Capital Limited
January
Page 2 12, 2023 Page 2
FirstName LastName
              rights to litigation settlements or court judgments, you perform
a probability-based
              outcome analysis of potential cash outflows to be received under
the proposed terms
              that explicitly applies a discount rate to take into
consideration the differences in
              timing of the potential cash flows. For example, tell us whether
your methodology
              discounts for time value the potential cash inflows that would
come from a future
              litigation settlement based on the expected timing of such a
settlement or stage of
              litigation, and if so, provide a representative example of how
this is done.
                Tell us whether any probability-based outcome analysis you
perform when deciding
              to enter into a capital provision rights agreement can be
reconciled to the initial
              purchase price paid for the capital provision asset. If not, tell
us why not.
                In response to prior comment 3, you stated that you are a
market participant under
              ASC Topic 820. To the extent you consider the impact of the time
value of money in
              determining the terms for entering into a capital provision
rights agreement, tell us
              whether you believe there would be any basis for not considering
changes to the time
              value of money (for example, market interest rate changes) on the
fair value of the
              capital provision assets each reporting period.
                Tell us whether you factor in other potential risks, such as
credit risk or foreign
              exchange risk, in determining the terms you would offer to
initially acquire a capital
              provision asset, or in subsequent fair value measurements. If
not, tell us why you do
              not believe a marketplace participant would consider this
information.
2.       To the extent that a capital provision rights agreement can be
resolved by a court
         judgment that includes additional compensation for time value, please
tell us whether you
         reflect the potential increase in cash inflows to be received under a
court judgement in
         your fair value estimate as of each measurement period. If so, tell us
how you reflect this
         potential increase in cash flows in your fair value estimate. If not,
tell us why not.
3.       We note your response to prior comment 4 where you provided your
policy to consider
         whether there are situations that arise, outside of an adjudicative
event, that result in a
         change to the estimated fair value of one of your capital provision
assets. Please respond
         to the following:
             Describe the procedures you put in place to determine when the
price that a market
              participant would pay to purchase one of your capital provision
assets would change,
              outside of an adjudicative event.
             Provide an example of how this policy was applied in one of these
situations, and the
              procedures performed to determine the appropriate fair value.
             Describe the documentation you maintain to support your
determination that events
              outside of adjudicative events do not have a material impact on
the fair value of your
              capital provision assets.
4.       We note your response to prior comment 6 where you described a
technique that relies on
         the identification of observable events that result in a percent of an
asset   s cost being
         recognized as a fair value loss or the percentage of the expected
profit being recognized as
         a fair value gain. Please respond to the following:
 Jordan Licht
FirstName  LastNameJordan  Licht
Burford Capital Limited
Comapany
January 12,NameBurford
            2023        Capital Limited
January
Page 3 12, 2023 Page 3
FirstName LastName
                Describe the analysis you use to develop the percentages you
apply to an asset   s cost
              for a particular observable event to determine the amount of fair
value loss.
                For fair value gains recognized, tell us how you develop the
expected profit and the
              related percentage to be applied for each material type of return
you earn on your
              capital provision assets (for example, time based returns,
multiple of funded capital,
              percentage of net realization, etc.).
                Outline for us the various groupings of capital provision
assets for which you have
              developed expected profit or loss percentages. Describe to us how
you have grouped
              these assets together, including your considerations related to
the asset vintage, asset
              type, case jurisdiction and adjudicative events.
                Discuss how frequently you have revised the percentages applied
using this
              technique, and what the driver of the revisions would be. When
percentages are
              revised, tell us whether these updated percentages are applied to
existing expected
              case outcomes at the next valuation date.
                To the extent you believe the percentages applied under this
policy capture the
              expected time horizon for recovery, tell us how. In addition,
tell us how you
              considered events impacting the expected time horizon of
resolution such as delays
              due to the COVID-19 pandemic.
5.       We note that the June 2022 (slide 9) and November 2022 (slide 12)
Investor Presentations
         available on your website include disclosure of the implied cash
realizations that you
         would receive from your capital provision assets based on a
probabilistic model.    Please
         tell us whether there are any events that would result in a change to
the implied cash
         realization for a capital provision asset in this probabilistic model
that do not result in a
         change to your estimate of the fair value of that capital provision
asset in accordance with
         ASC Topic 820. If so, explain what those events are, and why you
believe those events
         would not be considered by a marketplace participant.
6.       We note in your disclosure on page 31 that you continue to carry the
YPF-related assets
         (both Petersen and Eton Park combined) at the same carrying value
since June 2019, with
         the exception of increases in the cost basis due to costs deployed on
the assets since that
         date that are recoverable. Please describe the procedures you
performed to support the
         determination that there have not been any changes to relevant
information and market
         conditions since June 2019 that would materially impact what a market
participant would
         pay to acquire your YPF-related assets.
      You may contact Mark Brunhofer at 1-202-551-3638 or Sharon Blume at
1-202-551-
3474 with any questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
 Jordan Licht
Burford Capital Limited
FirstName
January 12,LastNameJordan
            2023          Licht
Page 4
Comapany   NameBurford Capital Limited
January 12, 2023 Page 4                  Office of Finance
FirstName LastName