August 20, 2019

Prof. Ugur Sahin, M.D.
Chief Executive Officer
BioNTech SE
An der Goldgrube 12
D-55131 Mainz
Germany

       Re: BioNTech SE
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted August 5, 2019
           CIK No. 0001776985

Dear Dr. Sahin:

      We have reviewed your amended draft 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 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.

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

Prospectus Summary
Our Pipeline, page 3

1.     We note your response to our prior comment 2 and reissue in part. Please
ensure that the
       graphical depiction of status in the table corresponds with the
disclosure in the prospectus
       regarding how far along each candidate is in the development process. In
this regard we
       note that all the arrows currently appear to show that all trials are
half-way complete.
2.     We note your response to our prior comment 3 and reissue in part. Please
tell us and
       revise your use of proceeds section to disclose whether and to what
extent you will use the
       proceeds from this offering in furtherance of the unidentified programs.
 Prof. Ugur Sahin, M.D.
BioNTech SE
August 20, 2019
Page 2
Business
XIV. Third-Party Collaborations, page 186

3.    Please disclose the up-front or execution payments received or paid under
the Genetech
      and Genmab collaboration agreements.
4.    We note your response to our prior comment 8 and reissue in part. Please
quantify the
      milestone and royalty payments under the Penn Agreement or explain to us
why you
      believe they are not material to an understanding of the agreement.
4 Revenue from contracts with customers, page F-31

5.    We acknowledge your response to prior comment 11. The revised disclosure
states that
      8.53 million was recognized as revenue under the Sanofi agreement in the
year ended
      2018. Please explain why this amount differs from the 41.71 million in
the table on page
      F-31.
        You may contact Vanessa Robertson at (202) 551-3649 or Lisa Vanjoske at
(202) 551-
3614 if you have questions regarding comments on the financial statements and
related matters.
Please contact Tonya K. Aldave at (202) 551-3601 or Justin Dobbie, Legal Branch
Chief, at
(202) 551-3469 with any other questions.



                                                           Sincerely,
FirstName LastNameProf. Ugur Sahin, M.D.
                                                           Division of
Corporation Finance
Comapany NameBioNTech SE
                                                           Office of Healthcare
& Insurance
August 20, 2019 Page 2
cc:       Eric Blanchard, Esq.
FirstName LastName