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                            August 18, 2023

       Marc de Garidel
       Chief Executive Officer
       Abivax SA
       7-11 boulevard Haussmann
       75009 Paris
       France

                                                        Re: Abivax SA
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted July 28,
2023
                                                            CIK No. 0001956827

       Dear Marc de Garidel:

             We have reviewed your amended 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.

       Amendment No. 1 to Draft Registration Statement on Form F-1, submitted
July 28, 2023

       Our Pipeline, page 3

   1.                                                   We note your response
to prior comment 4 and your revisions to the pipeline table. Please
                                                        revise your pipeline
table further to remove the row labeled "Obefazimod Follow-on." In
                                                        this regard we note
your disclosure that the first follow-on drug candidate in the Follow-
                                                        On Compounds Program is
not expected to be selected and enter into preclinical
                                                        development until 2024.
Alternatively, please explain how the Follow-On Compounds
                                                        Program is sufficiently
material to include in your pipeline table.
 Marc de Garidel
FirstName
Abivax SALastNameMarc de Garidel
Comapany
August 18, NameAbivax
           2023        SA
August
Page 2 18, 2023 Page 2
FirstName LastName
Our Strategy, page 6

2.       We note your disclosure on page 6 that your drug candidate has
displayed the potential for
         "durable efficacy and tolerability" in your Phase 2 trials. Please
remove references here,
         and elsewhere as appropriate, to your drug candidate's safety and
efficacy as those
         determinations are solely within the purview of the FDA and other
similar regulators.
Overview of Primary Endpoints of Induction Phase 2a Clinical Trial with
Obefazimod for
Treatment of UC, page 126

3.       We note your response to prior comment 13 and your revised disclosure
on page 126
         noting that the most frequently reported adverse events reported in
your Phase 2a trial
         included "GI disorders." Please revise your disclosure to describe
with more specificity
         the events that were observed in this regard or otherwise advise.
Evotec Drug Discovery Services Agreement, page 158

4.       We note your response to prior comment 15 and your revised disclosure
regarding the
         material terms of the Evotec Drug Discovery Services Agreement. Please
revise your
         disclosure further to state the total aggregate amount of fees that
could be due to Evotec
         for services provided under the agreement.
       You may contact Vanessa Robertson at 202-551-3649 or Mary Mast at
202-551-3613 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Joshua Gorsky at 202-551-7836 or Jason Drory at 202-551-8342 with any
other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Life
Sciences
cc:      Ryan Sansom