United States securities and exchange commission logo

                               January 29, 2021

       Bahija Jallal, Ph.D.
       Chief Executive Officer and Director
       Immunocore Holdings Limited
       92 Park Drive
       Milton Park
       Abingdon, Oxfordshire OX14 4RY
       United Kingdom

                                                        Re: Immunocore Holdings
Statement on Form F-1
                                                            Filed January 15,
                                                            File No. 333-252166

       Dear Dr. Jallal:

              We have reviewed your 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

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form F-1 filed January 15, 2021

       Prospectus Summary
       Our Pipeline, page 2

   1.                                                   We note your response
to prior comment 1 and the updated pipeline table. The arrows for
                                                        IMC-C103C, IMC-F106C,
GSK01 and IMC-I109V are drawn to the end of the Phase 1
                                                        column. However, your
disclosure in the Business section indicates that the Phase 1
                                                        portions of the
clinical trials for each of these product candidates are still ongoing. Please
                                                        shorten the arrows in
the pipeline chart to match the current status of each trial as
                                                        described in Business
or advise.
 Bahija Jallal, Ph.D.
FirstName  LastNameBahija    Jallal, Ph.D.
Immunocore     Holdings Limited
January 29,NameImmunocore
             2021              Holdings Limited
Page 2 29, 2021 Page 2
FirstName LastName
Phase 3 Clinical Trial, page 146

2.       Please revise your description of your Phase 3 clinical trial of
tebentafusp to provide
         safety and tolerability data including a description of any adverse
events and/or serious
         adverse events that were linked to treatment.
3.       We note your comparison of the observed hazard ratio in your Phase 3
trial of tebentafusp
         to the hazard ratios observed in several other Phase 3 trials of
treatments for uveal and
         cutaneous melanoma. Given that these were not head-to-head trials and
that the treatments
         in the control arms of the other trials in the table varied from the
control treatment in your
         trial, please tell us why you believe it is appropriate to include
these comparisons. Include
         in your response whether you expect to be able to rely on this data to
support an
         application for marketing approval from the FDA or comparable
regulatory body for
         commercialization of tebentafusp.
Additional ImmTAC Clinical Programs, page 148

4.       We note your response to prior comment 16 and updated disclosure.
Please revise to
         disclose the specific endpoints for the ongoing clinical trials
described in this section.
Financial Statements, page F-1

5.       Your audited financial statements are currently older than 12 months
and this is an initial
         public offering of your shares. Accordingly, please update your
financial statements
         pursuant to Item 8.A.4 of Form 20-F or provide the appropriate
representations in an
         exhibit. Refer to Instruction 2 to Item 8.A.4.

6.       The date of you auditor consent is January 15, 2020. Please have your
auditor provide an
         appropriately dated consent.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
 Bahija Jallal, Ph.D.
Immunocore Holdings Limited
January 29, 2021
Page 3

       You may contact Jenn Do at 202-551-3743 or Mary Mast at 202-551-3613 if
you have
questions regarding comments on the financial statements and related matters.
Please contact
Alan Campbell at 202-551-4224 or Jeff Gabor at 202-551-2544 with any other

FirstName LastNameBahija Jallal, Ph.D.
                                                          Division of
Corporation Finance
Comapany NameImmunocore Holdings Limited
                                                          Office of Life
January 29, 2021 Page 3
cc:       Courtney T. Thorne, Esq.
FirstName LastName