United States securities and exchange commission logo October 5, 2023 Marc de Garidel Chief Executive Officer Abivax SA 7-11 boulevard Haussmann 75009 Paris France Re: Abivax SA Registration Statement on Form F-1 Filed September 29, 2023 File No. 333-274780 Dear Marc de Garidel: We have reviewed your amended registration statement and have the following comment(s). Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our September 20, 2023 letter. Registration Statement on Form F-1 filed September 29, 2023 Dilution, page 86 1. Please explain why you did not deduct goodwill from total assets to calculate net tangible book value per share as of June 30, 2023. Marc de Garidel FirstName Abivax SALastNameMarc de Garidel Comapany October NameAbivax SA 5, 2023 October Page 2 5, 2023 Page 2 FirstName LastName Please contact Vanessa Robertson at 202-551-3649 or Mary Mast at 202-551-3613 if you have questions regarding comments on the financial statements and related matters. Please contact Joshua Gorsky at 202-551-7836 or Jason Drory at 202-551-8342 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Ryan Sansom