September 11, 2024

Kurt Gustafson
Executive Vice President, Finance and Chief Financial Officer
OmniAb, Inc.
5980 Horton Street, Suite 600
Emeryville, CA 94608

       Re: OmniAb, Inc.
           Form 10-K filed March 25, 2024
Dear Kurt Gustafson:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Year Ended December 31, 2023
Risk Factors, page 21

1.     Please expand the risk factor on page 30 to state whether the metrics
disclosed in your
       filings have historically been materially impacted by information from
partners that was
       subsequently found to be inaccurate. Such disclosure is necessary for
readers to fully
       assess the magnitude of the risk that you have identified.
Overview, page 65

2.     You disclose that you sell some licenses with upfront payments and some
licenses with
       annual payments. Please disclose any material differences in the license
rights your
       customers obtain when purchasing a license that requires only an upfront
payment as
       opposed to a license that requires annual payments. Disclose the license
duration terms
       normally granted to your customers i.e. 1 year, 5 years, etc. Disclose
the license
       termination rights granted to customers, whether the customer incurs any
       termination fees, and how this impacts your revenue recognition
policies. We may have
       further comment.
Key Business Metrics, page 67
 September 11, 2024
Page 2

3.     We have the following comments regarding your key business metrics:
           It appears that your definition of active partners and active
programs may have
          changed over the past several years. Please identify the changes made
for each metric,
          address the underlying reasons for those changes and indicate whether
or not those
          changes impacted the number of active partners and active programs
presented in
          each period;
           Please disclose on page 67 both the additions and terminations
impacting your active
          partner and active program metrics for all periods presented. The
impact of
          terminations is not clear. In this regard, we note your earnings
press release in Exhibit
          99.1 to your Item 2.02 Form 8-K filed on March 20, 2024, indicates
that you signed
          10 new licenses in 2023; however, your active partners increased by 8
from
          December 31, 2022 to December 31, 2023; and
           To the extent that any rights to an active program or licenses have
been terminated
          during the periods presented, please address the need to discuss such
terminations,
          including whether or not they may materially impact your future
revenues.
4.     Based on your definition of "Active Partners", it is not clear whether
this metric may
       include partners that are either not actively using their license or
have substantially ceased
       operations. Presumably this possibility exists given that your metric is
apparently not
       limited to customers with current and verified usage of their license.
It is also not clear
       how this metric differs from your total number of customers with
non-expired licenses.
       Please expand your disclosure on page 67 to clarify these issues and
also to clearly
       highlight the known uncertainties and limitations concerning this
metric.
5.     Based on your definition of "Active Programs", it is not clear whether
you apply a
       consistent time frame in characterizing your programs as "active".
Specifically, it is not
       clear whether your metric could include programs for which research work
commenced
       several years ago but for which no substantive work was performed in the
past year.
       Similarly, it is not clear if there is a time frame you are consistently
applying when you
       state that a "program is actively being developed or commercialized".
Further, it is not
       clear from your stated definition whether there are any inherent
uncertainties regarding
       your ability to objectively and accurately characterize a program as
"active". In this
       regard, we note the risk factor on page 30. Please expand your
disclosure on page 67 to
       clarify these issues and also highlight the known uncertainties and
limitations concerning
       this metric.
Revenue, page 67

6.     Please provide disclosure that correlates the changes in your key
business metrics to your
       changes in revenues. In this regard, while we note positive changes in
your metrics, your
       revenues continue to decline year over year.
7.     We note that in addition to the 2023 and 2022 milestones that materially
impacted your
       license and milestone revenues in those periods, you state that these
revenues also
       declined due to decreases in license and milestone revenue from other
programs. Please
       expand this disclosure to address the underlying reasons for this
decrease. Please also
       quantify the underlying reasons you reference related to the decrease in
service revenues.
Research and Development Expenses, page 68
 September 11, 2024
Page 3

8.     Please disclose the costs incurred during each period presented for each
of your
       key research and development projects or key programs separately. If you
do not track
       your research and development costs by project or program, please
disclose that fact and
       explain why you do not maintain and evaluate research and development
costs by project
       or program. For amounts that are not tracked by project or program,
provide other
       quantitative or qualitative disclosure that provides more transparency
as to the type
       of research and development expenses incurred (i.e. by nature or type of
expense), which
       should reconcile to total research and development expense on the
Statements of
       Operations.
       In closing, 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.

       Please contact Jeanne Baker at 202-551-3691 or Al Pavot at 202-551-3738
with any
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Industrial
Applications and
                                                          Services