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                             November 5, 2021

       Michael Leek
       Chief Executive Officer
       TC BioPharm (Holdings) Ltd
       Maxim 1, 2 Parklands Way
       Holytown, Motherwell, ML1 4WR
       Scotland, United Kingdom

                                                        Re: TC BioPharm
(Holdings) Ltd
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed October 27,
2021
                                                            CIK No. 0001872812

       Dear Dr. Leek:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
September, 2021 letter.

       Amendment No. 1 on Form F-1 filed October 27, 2021

       How can GD-Ts be used to treat disease?, page 70

   1.                                                   We note your response
to our prior comment 6 and your revisions. Please provide a brief
                                                        definition of
"transduction" where the term first appears on page 70.
       Clinical Outcome, page 75

   2.                                                   We note your response
to our prior comment 7 and your revisions. Please revise your
                                                        disclosure of the
QLC-C30 results to include a brief statement of the meaning of a lower
                                                        or higher QoL score. As
currently written, it is unclear whether a decrease in average QoL
                                                        scores is positively or
negatively associated with quality of life.
 Michael Leek
TC BioPharm (Holdings) Ltd
November 5, 2021
Page 2
Description of Share Capital and Articles of Association, page 109

3.    We note your estimated offering price range is $7 and $9 per share with a
mid-point of $8
      per share. As previously requested, please explain to us the reasons for
any differences
      between the recent valuation of your ordinary shares leading up to the
planned initial
      public offering and the midpoint of your estimated offering price range,
This information
      will help facilitate our review of your accounting for equity issuances.
       You may contact Angela Connell at 202-551-3426 or Christie Wong at
202-551-3684 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Jordan Nimitz at 202-551-5831 or Celeste Murphy at 202-551-3257 with
any other
questions.



                                                           Sincerely,
FirstName LastNameMichael Leek
                                                           Division of
Corporation Finance
Comapany NameTC BioPharm (Holdings) Ltd
                                                           Office of Life
Sciences
November 5, 2021 Page 2
cc:       Andrew Hudders, Esq.
FirstName LastName