September 17,
2024

Bharatt Chowrira
Chief Financial Officer
PureTech Health plc
6 Tide Street, Suite 400
Boston, MA 02210

        Re: PureTech Health plc
            Form 20-F for the fiscal year ended December 31, 2023
            Filed April 25, 2024
            File No. 001-39670
Dear Bharatt Chowrira:

       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 20-F for the fiscal year ended December 31, 2023
Notes to the Consolidated Financial Statements
Note 5. Investments at Fair Value, page F-22

1.      In 2023, you recognized a $61.7 million gain upon deconsolidation of
Vedanta and a
        $27.2 gain upon deconsolidation of Sonde in 2022. Please provide an
analysis supporting
        these loss-of-control conclusions, including your consideration of
Vedanta's issuance of
        convertible debt and Sonde's issuance of Series B preferred shares.
Also, provide detailed
        calculations supporting these deconsolidation gains, including key
assumptions used to
        determine fair value of your retained investment and a description and
quantification of
        specific assets and liabilities for Vedanta and Sonde prior to their
deconsolidation. In this
        regard, explain how you identified and valued assets and liabilities to
be deconsolidated
        with Vedanta and Sonde, and describe assets or liabilities associated
with these entities
        that remained in your consolidation (as applicable). Refer us to the
technical guidance
        upon which you relied. In addition, explain the impact on your ongoing
assessments of
        "power to control" and "significant influence" from contractual
arrangements and
 September 17, 2024
Page 2

       financing arrangements with these Founded Entities following their
deconsolidation.
       Revise your disclosure accordingly.
Note 8. Operating Expenses, page F-29

2.     Please provide a breakdown of research and development expenses by
development
       project for each period presented, distinguishing between retained
internal projects and
       those subject to partnered programs with Founded Entities. Ensure that
your response
       addresses all research and development activities discussed in Key
Performance
       Indicators on page 67 of your Annual Report. Revise your disclosure
accordingly.
       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 Frank Wyman at 202-551-3660 or Daniel Gordon at
202-551-3486 with
any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences
cc:   Charles Sherwood