December 19, 2018

Clive Richardson
Interim Chief Executive Officer
Akari Therapeutics Plc
75/76 Wimpole Street
London W1G 9RT
United Kingdom

       Re: Akari Therapeutics Plc
           Registration Statement on Form F-1
           Response dated December 6, 2018
           File No. 333-227752

Dear Mr. Richardson:

       We have reviewed your December 6, 2018 response to our comment letter
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 our 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 comment, we may have additional comments. Unless we
note
otherwise, our references to prior comments are to comments in our October 25,
2018 letter.

Form F-1 Filed October 9, 2018

General

1.     We refer to parts A and C.4 of your response to prior comment 1 and note
that your
       registration of 5 million ADS represents approximately 67% of your ADS
currently
       outstanding and held by non-affiliates. Given the size of the offering,
we cannot agree
       that this transaction can be made on a secondary basis in reliance on
Rule 415(a)(1)(i).
       Accordingly, please revise the Form S-1 to indicate that the offering
will be made at a
       fixed price or advise.
 Clive Richardson
Akari Therapeutics Plc
December 19, 2018
Page 2

       You may contact Jeffrey Gabor at 202-551-2544 or Joe McCann at
202-551-6262 with
any questions.



                                                       Sincerely,
FirstName LastNameClive Richardson
                                                       Division of Corporation
Finance
Comapany NameAkari Therapeutics Plc
                                                       Office of Healthcare &
Insurance
December 19, 2018 Page 2
cc:       Heidi Steele, Esq.
FirstName LastName