October 2, 2019

Rohan Palekar
Chief Executive Officer
89bio, Inc.
535 Mission Street, 14th Floor
San Francisco, CA 94105

       Re: 89bio, Inc.
           Amendment No. 1 Draft Registration Statement on Form S-1
           Submitted September 23, 2019
           CIK No. 0001785173

Dear Mr. Palekar:

      We have reviewed your amended draft 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 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 comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
September 12, 2019 letter.

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

Prospectus Summary
Our Company
Overview, page 1

1.     We note your revised disclosure on page 2 in response to comment 3.
Please clarify in
       your prospectus summary that you have not had a Special Protocol
Assessment or other
       agreement with the FDA with respect to the required clinical trials
needed to support an
       application for approval of BIO89-100 for the treatment of SHTG.
 Rohan Palekar
89bio, Inc.
October 2, 2019
Page 2
Our Lead Product Candiate, BIO89-100, page 2

2.       We note your response to comment 4 and your revised disclosure that
"[i]n these
         preclinical studies, consistent beneficial effects across a range of
endpoints were observed,
         including improvements in hepatic steatosis, injury and fibrosis in a
diet-induced NASH
         study of 50 mice . . . and improved glycemic control and lipid
handling in a study of 24
         spontaneously diabetic obese cynomolgus monkeys with elevated
triglycerides." Please
         avoid conclusory statements regarding the results of the tests, and
disclose the range of
         results observed in these tests.
Agreements with Teva
Agreements Relating to FGF21 Program, page 116

3.       We note your response to comment 10. Please disclose the payments, if
any, you are
         required to pay pursuant to the ratiopharm Sublicense Agreement.
       You may contact Andi Carpenter at 202-551-3645 or Angela Connell at
202-551-3426 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Sonia Bednarowski at 202-551-3666 or Dietrich King at 202-551-8071 with
any other

FirstName LastNameRohan Palekar                                Sincerely,
Comapany Name89bio, Inc.
                                                               Division of
Corporation Finance
October 2, 2019 Page 2                                         Office of Life
FirstName LastName