Babylon Holdings Limited

1 Knightsbridge Green

London, SW1X 7QA


May 4, 2022




United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-6010

Attention: Michael Davis


Re:           Babylon Holdings Limited

Registration Statement on Form F-1

File No. 333-264594


Ladies and Gentlemen:


In accordance with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the above referenced Registration Statement on Form F-1 (the “Registration Statement”) of Babylon Holdings Limited (the “Company”). We respectfully request that the Registration Statement become effective as of 4:00 p.m. Eastern Time on May 6, 2022, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Ryan Maierson at (713) 546-7420 or, in his absence, Julia Thompson at (202) 637-1073.


Thank you for your assistance in this matter.


  Very truly yours,
  By: /s/ Charles Steel
    Charles Steel
    Chief Financial Officer


cc:            Ryan J. Maierson, Latham & Watkins LLP

Julia Thompson, Latham & Watkins LLP