United States securities and exchange commission logo March 28, 2023 James Foster Chief Executive Officer Virax Biolabs Group Ltd 20 North Audley Street London, W1K 6LX United Kingdom Re: Virax Biolabs Group Ltd Registration Statement on Form F-1 Filed March 22, 2023 File No. 333-270734 Dear James Foster: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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 Lauren Hamill at 303-844-1008 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Lawrence Venick