United States securities and exchange commission logo

                           July 14, 2021

       Sean McClain
       Chief Executive Officer
       AbSci Corp
       101 E. 6th Street, Suite 350
       Vancouver, WA 98660

                                                        Re: AbSci Corp
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed July 8, 2021
                                                            File No. 333-257553

       Dear Mr. McClain:

             We have reviewed your amended registration statement and have the
       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.

       Amendment No. 1 to Registration Statement on Form S-1 Filed July 8, 2021

       Letter from Sean McClain, founder & CEO, page 120

   1.                                                   Please revise to
provide sources and/or citations for the following statements or
                                                        recharacterize them as
your beliefs:
                                                            "We   ve seen the
protein-based drug landscape grow exponentially."
pipelines are full of up-and-coming biologics, and the industry
                                                            has nearly
boundless ideas for new proteins that have yet to enter clinical
                                                            "Mammalian cells
are costly to maintain, slow and intractable to engineer, and
                                                            although they have
proven capable of making human antibodies, they are not readily
                                                            adaptable to making
new types of proteins."
                                                            "By marrying
cutting-edge artificial intelligence with synthetic biology, we are
 Sean McClain
AbSci Corp
July 14, 2021
Page 2
          stepping beyond the constraints of nature   s evolutionary
trajectory, opening up a new
          sequence space for potential proteins, and even adding new letters to
the amino acid
          alphabet to realize new possibilities for drug discovery."
Computational Antibody & Target Discovery, page 154

2.    We note your statement that "[t]his is a potentially powerful approach to
enable rapid
      response to emerging infectious diseases through efficient identification
of antibodies that
      could be useful for diagnostic and/or therapeutic interventions." Please
      supplemental support for this statement or recharacterize it as
management's beliefs.
       Please contact Cara Wirth at (202) 551-7127 or Mara Ransom at (202)
551-7127 with
any questions.

FirstName LastNameSean McClain
                                                            Division of
Corporation Finance
Comapany NameAbSci Corp
                                                            Office of Trade &
July 14, 2021 Page 2
cc:       Maggie Wong
FirstName LastName