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                              October 20, 2020

       Paraq Saxena
       Chief Executive Officer
       Eucrates Biomedical Acquisition Corp.
       250 W. 55th Street, Suite 13D
       New York, New York 10019

                                                        Re: Eucrates Biomedical
Acquisition Corp.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed October 15,
2020
                                                            File No. 333-249333

       Dear Mr. Saxena:

             We have reviewed your amended 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 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.
Unless we note
       otherwise, our references to prior comments are to comments in our
September 29, 2020 letter.

       Form S-1/A filed October 15, 2020

       Exhibit 4.4

   1.                                                   We note that the Form
of Warrant Agreement filed as Exhibit 4.4 provides that the
                                                        validity,
interpretation, and performance of the Warrant Agreement shall be brought and
                                                        enforced in the courts
of the State of New York or the United States District Court for the
                                                        Southern District of
New York, and irrevocably submits to such jurisdiction,    which
                                                        jurisdiction shall be
exclusive.    If this provision requires investors in this offering to
                                                        bring any such action,
proceeding or claim in the courts of the State of New York or the
                                                        United States District
Court for the Southern District of New York, please disclose such
                                                        provision in your
registration statement, and disclose whether this provision applies to
                                                        actions arising under
the Securities Act or Exchange Act. If the provision applies to
 Paraq Saxena
Eucrates Biomedical Acquisition Corp.
October 20, 2020
Page 2
      actions arising under the Securities Act or Exchange Act, please also add
related risk
      factor disclosure clearly and prominently describing the provision,
describing any risks or
      other impacts on investors, and to state that there is uncertainty as to
whether a court
      would enforce such provision and that investors cannot waive compliance
with the federal
      securities laws and rules and regulations thereunder. If this provision
does not apply to
      actions arising under the Securities Act or Exchange Act, please also
ensure that the
      provision in the Warrant Agreement states this clearly.
Exhibit 5.1

2.    We note that your legal opinion, filed as Exhibit 5.1, opines on the
legality of the ordinary
      shares issuable upon the exercise of your warrants. We also note that you
have not
      registered the ordinary shares issuable upon the exercise of your
warrants on this
      registration statement. Please revise accordingly.
       You may contact Charles Eastman, Staff Accountant, at (202) 551-3794 or
Martin James,
Senior Advisor, at (202) 551-3671 if you have questions regarding comments on
the financial
statements and related matters. Please contact Sergio Chinos, Staff Attorney,
at (202) 551-
7844 or Sherry Haywood, Staff Attorney, at (202) 551-3345 with any other
questions.



                                                            Sincerely,
FirstName LastNameParaq Saxena
                                                            Division of
Corporation Finance
Comapany NameEucrates Biomedical Acquisition Corp.
                                                            Office of
Manufacturing
October 20, 2020 Page 2
cc:       Daniel Forman
FirstName LastName