July 16, 2019

Zhengbin Yao, Ph.D.
Chairman, President and Chief Executive Officer
Viela Bio, Inc.
One Meddimune Way
First Floor, Area Two
Gaithersburg, MD 20878

       Re: Viela Bio, Inc.
           Draft Registration Statement on Form S-1
           Submitted June 17, 2019
           CIK No. 0001734517

Dear Dr. Yao:

       We have reviewed your draft 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form S-1

Prospectus Summary
Overview, page 1

1.     Please remove the characterization of your company as "emerging
commercial-stage"
       given that you have yet to receive FDA approval for your lead product
candidate and have
       yet to commercialize any product candidates.
Our Pipeline, page 2

2.     We note that your pipeline table indicates that Phase 1 testing for
VIB7734 is complete.
       However, the discussion indicates you are conducting a Phase 1b trial.
Please revise your
 Zhengbin Yao, Ph.D.
FirstName Inc.
Viela Bio, LastNameZhengbin Yao, Ph.D.
Comapany NameViela Bio, Inc.
July 16, 2019
July 16, 2019 Page 2
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FirstName LastName
         table to indicate that you have not completed Phase 1 testing by
shortening the bar so that
         it does not extent all the way through the Phase 1 column.
3.       We note that your pipeline table includes two preclinical programs
that you are exploring.
         As you only discuss these programs very briefly in the prospectus and
you have not
         allocated any proceeds for their development in your use of proceeds
section, please
         provide us your analysis supporting your determination to include them
in your pipeline
         table. If they are material, please revise your table to more
specifically identify the
         indication, and revise the bar graph to indicate that preclinical
trials have not been
         completed.
Our Strategy, page 4

4.       We note your disclosure that your strategy is to "rapidly advance"
VIB4920 and VIB7734
         through clinical development for multiple diseases with shared
critical biological
         pathways. Please revise this disclosure to remove any implication that
you will be
         successful in commercializing your product candidates in a rapid or
accelerated manner as
         such statements are speculative.
Implications of Being an Emerging Growth Company, page 7

5.       Please supplementally provide us with copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
         not they retain copies of the communications.
Some intellectual property may have been discovered through government funded
programs,
page 49

6.       We note your disclosure that the U.S. government may have certain
rights to intellectual
         property embodied in certain of your current or future product
candidates. Please identify
         the intellectual property and the related product candidates.
If we fail to comply with our obligations in the agreements under which we
license intellectual
property, page 52

7.       We note your disclosure that you could lose license rights that are
important to your
         business if you fail to comply with your obligations under certain
license agreements.
         Please identify the license agreements and the related product
candidates.
Use of Proceeds, page 70

8.       Please disclose how far you expect the proceeds from the offering to
allow you to proceed
         in the development of each of your programs.

Management's Discussion and Analysis of Financial Condition and Results of
Operations
 Zhengbin Yao, Ph.D.
FirstName Inc.
Viela Bio, LastNameZhengbin Yao, Ph.D.
Comapany NameViela Bio, Inc.
July 16, 2019
July 16, 2019 Page 3
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FirstName LastName
Research and Development Expenses , page 83

9.       You disclose that $34.2 million of your research and development
expenses consisted of
         direct program and external costs, including primarily clinical trials
of inebilizumab,
         VIB4920 and VIB 7734. Please revise to quantify your research and
development
         expenses by product candidate. If you do not keep track of such costs
by product
         candidate, disclose that fact.
Critical Accounting Policies and Significant Judgments and Estimates
Stock-Based Compensation Expense - Common stock valuations, page 87

10.      Once you have an estimated offering price or range, please explain to
us the reasons for
         any differences between the recent valuations of your common stock and
the estimated
         offering price. This information will help facilitate our review of
your accounting for
         equity issuance including stock compensation and beneficial conversion
features.
Other Company Information
Emergency Growth Company Status, page 90

11.      You disclose that you have elected to apply the extended transition
period under the JOBS
         Act for complying with new or revised accounting standards. However,
you state in
         your risk factor disclosure on page 64 that you have irrevocably
elected not to avail
         yourself to this exemption. Please revise to correct this apparent
inconsistency.
Duke License Agreement, page 118

12.      Please disclose when the last-to-expire licensed patent is currently
scheduled to expire.
DFCI License Agreement, page 119

13.      Please disclose when the last-to-expire of the licensed patents in
each applicable country
         is currently scheduled to expire.
BioWa/Lonza Sublicense Agreement, page 121

14.      Please disclose when the BioWa/Lonza license terminates.
Lonza Sublicense Agreement, page 121

15.      Please disclose when the MedImmune license agreement with Lonza
terminates.
Principal Stockholders, page 167

16.      Please revise your disclosure to identify the natural person or
persons who have voting
         and investment control of the shares held by Boundless Meadow Limited,
6 Dimensions
         Capital, L.P., 6 Dimensions Affiliate Fund, L.P., HH RSV-MIM Holdings
Limited
         and TLS Beta Pte. Ltd.
 Zhengbin Yao, Ph.D.
Viela Bio, Inc.
July 16, 2019
Page 4
Exclusive Jurisdiction of Certain Actions, page 175

17.      We note your disclosure that your exclusive forum provision does not
apply to any actions
         arising under the Securities Act or the Exchange Act. Please ensure
that the exclusive
         forum provision in the governing documents clearly states that it does
not apply to actions
         arising under the Securities Act or Exchange Act or tell us how you
will inform investors
         in future filings that the provision does not apply to any actions
arising under the
         Securities Act or Exchange Act.
General

18.      Please provide us proofs of all graphics, visual, or photographic
information you will
         provide in the printed prospectus prior to its use, for example in a
preliminary prospectus.
         Please note that we may have comments regarding this material.
       You may contact Andi Carpenter at 202-551-3645 or Angela Connell at
202-551-3426 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Ada Sarmento at 202-551-3798 or Suzanne Hayes at 202-551-3675 with any
other
questions.



FirstName LastNameZhengbin Yao, Ph.D.                          Sincerely,
Comapany NameViela Bio, Inc.
                                                               Division of
Corporation Finance
July 16, 2019 Page 4                                           Office of
Healthcare & Insurance
FirstName LastName