United States securities and exchange commission logo December 12, 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-3 Filed December 5, 2023 File No. 333-275893 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 Cindy Polynice at 202-551-8707 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Rongwei Xie