United States securities and exchange commission logo October 17, 2023 Marc de Garidel Chief Executive Officer Abivax SA 7-11 boulevard Haussmann 75009 Paris France Re: Abivax SA Amendment No. 1 to Registration Statement on Form F-1 Filed October 16, 2023 File No. 333-274780 Dear Marc de Garidel: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe the 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 October 5, 2023 letter. Amendment No. 1 to Registration Statement on Form F-1, filed October 16, 2023 Capitalization, page 85 1. Please revise the description in the second bullet to quantify separately the amount of the tranches drawn for the Kreos/Claret OCABSA and Heights Convertible Notes as well as the amounts repaid under the First KC Agreement, the Second KC Agreement and the OCEANE bonds. Marc de Garidel FirstName Abivax SALastNameMarc de Garidel Comapany October 17,NameAbivax 2023 SA October Page 2 17, 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