1 Knightsbridge Green 

London, SW1X 7QA 

United Kingdom


June 15, 2022


Via Edgar


Securities and Exchange Commission 

Division of Corporation Finance

100 F Street, N.E. 

Washington, D.C.  20549-6010 

Attention: Jason Drory


Re:Babylon Holdings Limited
  Registration Statement on Form F-4
  File No. 333-265128


To the address set forth above:


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-4 (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 June 17, 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, Charles Cassidy at (202) 637-2176.


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 A. Thompson, Latham & Watkins LLP
 R. Charles Cassidy III, Latham & Watkins LLP