United States securities and exchange commission logo

                              November 12, 2020

       Nima M. Farzan
       President and Chief Executive Officer
       Kinnate Biopharma Inc.
       11875 El Camino Real, Suite 101
       San Diego, California 92130

                                                        Re: Kinnate Biopharma
                                                            Amendment No. 2 to
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted November
3, 2020
                                                            CIK No. 0001797768

       Dear Ms. Farzan:

               We have reviewed your amended draft registration statement and
have the following
       comment. 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 comment applies to your facts and
circumstances or do
       not believe an amendment is appropriate, please tell us why in your

             After reviewing the information you provide in response to this
comment and your
       amended draft registration statement or filed registration statement, we
may have additional

       Amendment No. 2 to Draft Registration Statement on Form S-1

       Certain Relationships and Related Party Transactions, page 180

   1.                                                   We note your response
to comment 1; however, as Item 404 requires disclosure for
                                                        transactions since the
beginning of the company's last fiscal year, including disclosure of
                                                        the name of the related
person and the basis on which the person is a related person, the
                                                        identity of the
beneficial owner or owners of Eschelman Ventures LLC who are related
                                                        persons are required to
be disclosed, unless one of the exceptions in the Instructions
                                                        to Item 404(a) apply.
Please advise.
 Nima M. Farzan
FirstName LastNameNima
Kinnate Biopharma  Inc. M. Farzan
Comapany 12,
November  NameKinnate
              2020      Biopharma Inc.
Page 2    12, 2020 Page 2
FirstName LastName
        You may contact Julie Sherman at (202) 551-3640 or Angela Connell at
(202) 551-
3426 if you have questions regarding the financial statements and related
matters. Please contact
Abby Adams at (202) 551-6902 or Celeste Murphy at (202) 551-3257 with any other


                                                            Division of
Corporation Finance
                                                            Office of Life
cc:      Tony Jeffries, Esq.