United States securities and exchange commission logo

                            August 12, 2021

       Jennifer Buell, Ph.D.
       President, Chief Executive Officer and Director
       MiNK Therapeutics, Inc.
       149 Fifth Avenue
       Suite 500
       New York, NY 10010

                                                        Re: MiNK Therapeutics,
                                                            Amendment No. 2 to
Draft Registration Statement on Form S-1
                                                            Submitted July 28,
                                                            CIK No. 0001840229

       Dear Dr. Buell:

            We have reviewed your amended draft registration statement and have
the following

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comment applies to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your

             After reviewing the information you provide in response to this
comment and your
       amended draft registration statement or filed registration statement, we
may have additional

       Amendment No.2 to Draft Registration Statement on Form S-1

       Key Features of iNKT Cells
       Naturally Suited for Allogeneic Approaches, page 83

   1.                                                   We note your disclosure
that "[i]n both clinical and preclinical studies, iNKT cells have
                                                        been observed not to
cause, but instead to actively suppress, GvHD, lowering the safety
                                                        risks associated with
other allogeneic immune cells." With reference to your disclosure
                                                        on page 14, please
revise the disclosure on page 83 to provide context to these
                                                        observations by
explaining, if true, that no allogeneic iNKT cell therapy has been deemed
                                                        safe or been approved
by FDA or by any comparable regulatory authority.
 Jennifer Buell, Ph.D.
FirstName  LastNameJennifer   Buell, Ph.D.
MiNK Therapeutics,    Inc.
August  12, NameMiNK
            2021         Therapeutics, Inc.
Page 2 12, 2021 Page 2
FirstName LastName
       You may contact Nudrat Salik at 202-551-3692 or Daniel Gordon at
202-551-3486 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Dillon Hagius at 202-551-7967 or Joe McCann at 202-551-6262 with any


                                                        Division of Corporation
                                                        Office of Life Sciences
cc:      Zachary Blume